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OF CUMBERLAND COUNTY
STATE OF
PENNA.
..IMMANUEL -RANDOLPH-,..-
....n.-Plail1tifL-,-
NO.20-0-1--23-8.3 ................., 19
I
Versus
-. CRY-STAL---R,RANDOLPH,
, "'flerendant....---..,-
DECREE IN
DIVORCE
AND NOW, . Sept.ember. 1.2.; . :2-00.1. .. " ......., it is ordered and
decreed that ... IMMANUE'I; 'RANDOLPH . . . . . . . . . . . . . . . . . . . . . . . . " plaintiff,
and. . . . . . . . . . . . CRY5TA:L' R'.' 'RANDOLPH' . . . . . . . . . . . . . . . . . . . . " defendant,
are divorced from the bonds of matrimony.
The court retains jurisdiction of the following claims which have
been raised of record in this action for which a final order has not yet
been entered;
"NONE" .. .. .. . . . . . . .. .. .. .. .. .. . . .. . . . . .. . . . . .. . .. . .. .. . . .. .. . . .. .. .. .. . . .
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HAROLD S. IRWIN, III, ESQUIRE
ATTORNEY ID NO. 29920
35 EAST HIGH STREET
CARLISLE PA 17013
(717) 243-6090
ATTORNEY FOR PLAINTIFF
IMMANUEL RANDOLPH,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: NO. 01 - 2383 CIVIL TERM
CRYSTAL R. RANDOLPH,
Defendant
ORDER OF COURT
NOW, this day of August, 2002, in consideration of the attached
petition, it is hereby directed that the parties and their respective counsel appear before
Hubert X. Gilroy, Esquire, the conciliator, on the 4th Floor, Cumberland County
Courthouse, on the day of , 2002, 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. Failure to appear at this
conference may provide grounds for entry of a temporary or permanent order.
By the Court,
By:
Custody Conciliator
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
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HAROLD S. IRWIN, III, ESQUIRE
ATTORNEY ID NO. 29920
35 EAST HIGH STREET
CARLISLE PA 17013
(717) 243-6090
ATTORNEY FOR PLAINTIFF
IMMANUEL RANDOLPH,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: NO. 01 - )~ CIVIL TERM
CRYSTAL R. RANDOLPH,
Defendant
: IN DIVORCE
ORDER OF COURT
NOW, this day of April, 2001, in consideration of the attached petition, it
is hereby directed that the parties and their respective counsel appear before Hubert X.
Gilroy, Esquire, the conciliator, on the 4th Floor, Cumberland County Courthouse, on
the day of , 2001, 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. Failure to appear at this conference may
provide grounds for entry of a temporary or permanent order.
By the Court,
By:
Custody Conciliator
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
"'All'll'_ _ _',__", _,,,,"__~ '~",'~"-_q_ ",.'h~~~_'W_~__>'"'M_ ~,~.~'^" ".
HAROLD S. IRWIN, III, ESQUIRE
ATTORNEY ID NO. 29920
35 EAST HIGH STREET
CARLISLE PA 17013
(717) 243-6090
ATTORNEY FOR PLAINTIFF
IMMANUEL RANDOLPH,
Plaintiff
= IN THE COURT OF COMMON PLEAS OF
= CUMBERLAND COUNTY, PENNSYLVANIA
v.
= CIVIL ACTION - LAW
= NO. 01 - .23 f3 CIVIL TERM
CRYSTAL R. RANDOLPH,
Defendant
= IN DIVORCE
NOTICE
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 in 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 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 17013.
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 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) 240-6200
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IMMANUEL RANDOLPH,
Plaintiff
= IN THE COURT OF COMMON PLEAS OF
= CUMBERLAND COUNTY, PENNSYLVANIA
v.
= CIVIL ACTION - LAW
= NO. 01 - .l3f3 CIVIL TERM
CRYSTAL R. RANDOLPH,
Defendant
= IN DIVORCE
COMPLAINT IN DIVORCE
PU~S~~NT TO S~CTION 2201 ~ OF THE DIVORC.E CO~E
NOW, comes the plaintiff, Immanuel Randolph, by his attorney, Harold S. Irwin,
III, Esquire, and files this complaint in divorce against the defendant, Crystal R.
Randolph, representing as follows:
1. The plaintiff is Immanuel Randolph, an adult individual residing at 11
Longstreet Drive, Carlisle, Cumberland County, Pennsylvania 17013.
2. The defendant is Crystal R. Randolph, an adult individual whose present
residence is unknown but whose parents are as follows: Mr. & Mrs. William Cooper,
401 Oceanwind Road, Bear, Delaware.
3. The parties have been residents of the Commonwealth of Pennsylvania at
least six months immediately prior to the filing of this action in divorce.
4. The plaintiff and the defendant were married in February, 1998, in Elkton,
Maryland.
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5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the
grounds upon which this action is based that the marriage between the parties is
irretrievably broken.
6. The plaintiff avers that he has been advised of the availability of
counseling and that said party has the right to request that the court require the parties
to participate in counseling.
WHEREFORE, the plaintiff demands judgment dissolving the marriage between
the two parties.
April n, 2001
HAROLD S. IRWIN, III
Attorney for Plaintiff
VERIFICATION
I verify that the facts contained herein are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904
relating to unsworn falsification to authorities.
April n , 2001
~/~
IMMANUEL RANDOLPH Plaintiff
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IMMANUEL RANDOLPH,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: NO. 01 - .23 f3 CIVIL TERM
CRYSTAL R. RANDOLPH,
Defendant
: IN DIVORCE
PETITION FOR CUSTODY
NOW comes the plaintiff, Immanuel Randolph, by his attorney, Harold S. Irwin,
III, Esquire, and presents the following petition for custody, representing as follows:
1. The plaintiff is Immanuel Randolph, an adult individual residing at 11
Longstreet Drive, Carlisle, Cumberland County, Pennsylvania 17013.
2. The defendant is Crystal R. Randolph, an adult individual residing at 401
Oceanwind Road, Bear, Delaware.
3. The parties are the parents of a minor daughter, namely Selena Carrie
Randolph (born April 1 0, 2001, age 2 years).
4. The child resided with the parties from the time of her birth until April 4,
2001, when the defendant abandoned the marital home with the child. Since that time
the child has lived with defendant, who has failed to communicate with the plaintiff since
separation or offer to permit visitation and partial custody of the child by the plaintiff.
5. 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, other than the existing Order filed to this term and number.
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6. 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.
7. Plaintiff believes and therefor avers that the best interests and permanent
welfare of the child require that the parties have joint legal and physical custody of the
child in accordance with a schedule and under certain conditions which may be agreed
upon at a conciliation to be held in this matter.
WHEREFORE, plaintiff respectfully requests that the court enter an order
providing for the legal and physical custody of the child as aforesaid.
HAROLD S. IRWIN, II
Attorney f~r plainti
,
April (7, 2001
35 East High Street
Carlisle, Pennsylvania 17013
(717) 243-6090
Supreme Court 1.0. No. 29920
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VERIFICATION
I do hereby verify that the acts set forth in this petition 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.
April L.2-. 2001
~1'/~~
IMMANUEL RANDOLPH
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IMMANUEL RANDOLPH
PLAINTIFF
V.
CRYSTAL R. RANDOLPH
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
01-2383 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW,
Friday, April 27, 2001
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, May 09, 2001 at 2:30 p.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.
The court hereby directs the parties to furnish auy and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: Isl
Jacqueline M. Verney. Esq./JP
Custody Conciliator
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 THIS 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
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01 APR 27 Pti I: 5 !
CUM8E:HL.AND COUNTY
PENNSYLVANiA
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IMMANUEL RANDOLPH
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
01-2383 CIVIL ACTION LAW
CRYSTAL R. RANDOLPH
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW, Wednesday, August 28, 2002 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, September 18, 2002 at 2:30 PM
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.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearinll.
FOR THE COURT,
By: Isl
Jacqueline M. Verney, Esq.
Custody Conciliator
p
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 THIS 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
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IMMANUEL RANDOLPH,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION. LAW
: NO. 01 - 2383 CIVIL TERM
CRYSTAL R. RANDOLPH,
Defendant
PETITION FOR MOD!IFICATIONOF CUSTODY
NOW comes the plaintiff, Immanuel Randolph, by his attorney, Harold S. Irwin,
III, Esquire, and presents the following petition for modification of custody, representing
as follows:
1. The plaintiff is Immanuel Randolph, an adult individual residing at 1640 -
201 Wimbledon Way, Greenville, North Carolina 27858.
2. The defendant is Crystal R. Randolph, an adult individual residing at P. O.
Box 91, Greenwood, Delaware 19950.
3. The parties are the parents of a minor daughter, namely Selena Carrie
Randolph (born April 1 0, 2001, age 2 years).
4, The child resided with the parties from the time of her birth until April 4,
2001, when the defendant abandoned the marital home with the child. Since that time
the child has lived with defendant, subject to periods of temporary custody with the
plaintiff in accordance with an agreement of the parties and an Order of Court dated
May 13, 2001, a copy of which is attached as Exhibit "An. In addition, during most
months since the entry of said Order, the plaintiff has had the child for longer periods
than that provided for in the Order.
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5. 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, other than the existing Order filed to this term and number.
6. 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.
7. Plaintiff believes and therefor avers that the best interests and permanent
welfare of the child require that the current Order of Court be modified in that since the
entry of said Order, plaintiff has moved from Carlisle, Pennsylvania, to Greenville, North
Carolina.
8. Due to the distances involved, plaintiff believes and therefore avers that
the parties should select a location for the exchange of custody that requires each party
to travel approximately the same amount of time and also that the parties should
alternate custody of the child on a monthly basis.
WHEREFORE, plaintiff respectfully requests that the court enter an order
providing for the modification of the physical custody arrangements for the child as
aforesaid.
HAROLD S. IRWIN, III
Attorney for plaintiff
Augustd" 2002
35 East High Street
Carlisle, Pennsylvania 17013
(717) 243.6090
Supreme Court 1.0. No. 29920
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VERIFICATION
I do hereby verify that the acts set forth in this petition 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.
August ..L!L, 2002
J~,.~~J.~
IMMANUEL NDOLPH
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HAROLD S. IRWIN, III, ESQUIRE
ATTORNEY ID NO. 29920
35 EAST HIGH STREET
CARLISLE PA 17013
(717) 243-6090
ATTORNEY FOR PLAINTIFF
IMMANUEL RANDOLPH,
Plaintiff
= IN THI: COURT OF COMMON PLEAS OF
= CUMBERLAND COUNTY, PENNSYLVANIA
v.
= CIVIL ACTION - LAW
= NO. 01 - 2383 CIVIL TERM
CRYSTAL R. RANDOLPH,
Defendant
= IN DIVORCE
AFFIDAVIT OF SERVICE OF COMPLAINT
PURSUANT TO PA. R.C.P. RULE NO. 1920.4 <Ml.1.lill
NOW, Harold S. Irwin, III, Esquire, being duly sworn according to law, does
depose and state:
1. That he is a competent adult and attorney for the plaintiff in the above
captioned action in divorce.
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2. That a certified copy of the complaint in divorce was served upon the
defendant on or about April 27, 2001, by certified mail "restricted delivery", addressed
to her c/o M/M William Cooper, 401 Oceanwind Road, Bear, DE, certified mail, return
receipt No. Z 339 062 176,
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3. That a copy of the sender's receipt and signed receipt for certified mail is
attached hereto.
I verify that the statements made in this affidavit are true and correct. I
understand that false statements herein made are subject to the penalties of 18 Pa. C.
S. Section 4904, relating to unsworn falsification to uthorities,
May 1, 2001
Harold S. Irwin, III
Attorney for plaintiff
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IMMANUEL RANDOLPH,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
.
.
v.
: CIVIL ACTION - LAW
: NO. 01" .:.. 2383 CIVIL TERM
CRYSTAL R. RANDOLPH,
Defendant
: IN DIVORCE
PLAINTIFF"S AFFIDAVIT OF CONSENT
1. A complaint in divorce under Section 3301(c) of the Divorce Code was
filed in this matter on or about April 23, 2001 and served upon defendant on or about
April 27, 2001.
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2, The marriage of plaintiff and defendant is irretrievably broken and ninety
days have elapsed from the date of the 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 divorce.
I verify that the statements made in this affidavit are true and correct. I
understand that false statements herein made are subject to the penalties of 18 Pac C.
S. Section 4904 relating to unsworn falsification to authorities.
~t ,2001
~~~
IMMANUEL RANDOLPH
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IMMANUEL RANDOLPH,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
: CIVIL ACTION. LAW
: NO. 01 - 2383 CIVIL TERM
CRYSTAL R. RANDOLPH,
Defendant
: IN DIVORCE
)'VAIV,lR OF NOTICE OF INTEI'flJON 'to REQUEST
~NLRY 01;' A DIVORCE DECREE
UNDEI~"J;ECTION 3301 aa-OF_THE g,IVOR~E COPE
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.
Section 4904 relating to unsworn falsification to authorities.
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IMMANUEL RANDOLP
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IMMANUEL RANDOLPH,
Plaintiff
= UN THE COURT OF COMMON PLEAS OF
= CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
= NO. 01 - 2383 CIVIL TERM
CRYSTAL R. RANDOLPH,
Defendant
= IN DIVORCE
PLAINTIFF"S MARRIAG,E COUNSELING AFFIDAVIT
1. I have been advised of the availability of marriage counseling and
understand that I may request that the court require that my spouse and I participate in
counseling.
2. I understand that the court maintainsallst of marriage counselors in the
Prothonotary's Office, which list is available to me upon request.
3. Being so advised, I do not request that the court require that my spouse
and I participate in counseling prior to a divorce decree being handed down.
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.
~/,2001
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IMMANUEL RANDOLPH,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: INO. 01 - 2383 CIVIL TERM
CRYSTAL R, RANDOLPH,
Defendant
: IN DIVORCE
DEFENDANT"S AFFIDAVIT OF CONSENT
1. A complaint in divorce under Section 3301 (c) of the Divorce Code was
filed in this matter on or about April 23, 2001 and served upon defendant on April 27,
2001.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety
days have elapsed from the date of the 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 divorce.
I verify that the statements made in this affidavit are true and correct.
understand that false statements herein made are subject to the penalties of 18 Pac C.
S. Section 4904 relating to unsworn falsification to authorities.
September 2. 2001
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Y TAL R. RANDOLPH
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IMMANUEL RANDOLPH,
Plaintiff
= IN THE COURT OF COMMON PLEAS OF
= CUMBERLAND COUNTY, PENNSYLVANIA
v.
= CIVIL ACTION - LAW
= INO. 01 - 2383 CIVIL TERM
CRYSTAL R, RANDOLPH,
Defendant
= IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
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~NTRX. ot A DIVORCE gECREI5,
YNDER_SECTIOf! 3~01.IJa. OF Tt!E DIVORCE ~DI5,
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.
Section 4904 relating to unswom falsification to authorities.
September 7, 2001
~PR. .gnqJ~
R TAL R. RANDOLPH
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Plaintiff
: UN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
v.
: CIVIL ACTION - LAW
: NO. 01 - 2383 CIVIL TERM
CRYSTAL R. RANDOLPH,
Defendant
: IN DIVORCE
D,EFEN,DANT"S MARRIAGE COUNSELING AFFIDAVIT
The defendant, being duly sworn according to law, deposes and says:
1. I have been advised of the availability of marriage counseling and
understand that I may request that the court require that my spouse and I participate in
counseling.
2. I understand that the court maintains a list of marriage counselors in the
Prothonotary's Office, which list is available to me upon request.
3. Being so advised, I do not request that the court require that my spouse
and I participate in counseling prior to a divorce decree being handed down,
I verify that the statements made in this affidavit are true and correct.
understand that false statements herein made are subject to the penalties of 18 Pac
C.S. Section 4904, relating to unsworn falsification to authorities.
September 7 ,2001
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HAROLD S. IRWIN, III, ESQUIRE
ATTORNEY ID NO. 29920
35 EAST HIGH STREET
CARLISLE PA 17013
(717) 243-6090
ATTORNEY FOR PLAINTIFF
IMMANUEL RANDOLPH,
Plaintiff
; IN THE COURT OF COMMON PLEAS OF
; CUMBERLAND COUNTY, PENNSYLVANIA
v.
; CIVIL ACTION - LAW
; NO. 01 - 2383 CIVIL TERM
CRYSTAL R. RANDOLPH,
Defendant
; IN DIVORCE
PRAECIPE TO TRANS,MIT 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 and manner of service of the complaint: On or about April 27, 2001, defendant was
served with a copy of the divorce complaint. See Affidavit of Service filed on May 1,
2001.
3. Complete either paragraph (a) or (b):
(a) Date of execution of consent required by Section 3301 (c) of the Divorce Code:
By the plaintiff: August 1, 2001.
By the defendant: September 7, 2001.
(b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce
Code: N/A.
(b)(2) Date of filing and service of the plaintiffs affidavit upon the defendant: N/A.
4. Related claims pending: None
5. Complete either (a) or (b):
(a) Date and manner of service of the notice of intention to file praecipe to transmit
record, a copy of which is attached: N/A
(b) Date plaintiffs Waiver of Notrice in Section 3301(c) divorce was filed with the
Prothonotary: August 1, 2001.
Date defendant's Waiver of Notice in Section 3301@ Divorce was filed with the
Prothonotary: September 10, 2001.
/
/
HAROLD S. IRWIN, III
Attorney for Plaintiff
September 20, 2001
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SEP 1 9 2002
IMMANUEL RANDOLPH,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: CIVIL ACTION - LAW
CRYSTAL R. RANDOLPH,
Defendant
: NO. 2001-2383 CIVIL TERM
: IN CUSTODY
ORDER OF COURT
AND NOW, this \ '1M day of ~ftc -, L cF ,2002, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
1. A Hearing is scheduled in Court Room No. I ,of the Cumberland
County Court House, on the /3 t:Jv day of lCk .NJ~ , 2002, at I; 3 ()
o'clock, -f!-o.. M., at which time testimony will be taken. For purposes of this Hearing,
the Father shall be deemed to be the moving party and shall proceed initially with
testimony. Counsel for each party shall file with the Court and opposing counsel a
Memorandum setting forth each party's position on custody, a list of witnesses who will
be expected to testify at the Hearing and a summary of the anticipated testimony of each
witness. These Memoranda shall be filed at least ten days prior to the Hearing date.
2. The Order of Court dated May 13, 2001 shall remain in full force and
effect except that Paragraph 4 thereof is vacated and replaced with the following:
3. The parties shall share transportation such that exchanges shall occur
either at the north or south end of the Chesapeake Tunnel, with the receiving party
driving the farther distance.
4. The parties may modify this Order by mutual agreement. In the absence
of mutual consent, the terms of this Order shall control.
BY THE COURT,
cc: Harold S. Irwin, III, Esquire, counsel for
Crystal R. Randolph, pro se
In Loquitur Lane
Magnolia, Delaware 19962
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IMMANUEL RANDOLPH,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLV ANlA
V.
: CIVIL ACTION - LAW
CRYSTAL R. RANDOLPH,
Defendant
: NO. 2001-2383 CIVIL TERM
: IN CUSTODY
PRIOR JUDGE: J. Wesley Oler, Jr., J.
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
Selena Carrie Randolph April 10, 1999
Mother
2. A Conciliation Conference was held September 18, 2002 with the
following individuals in attendance: The Father, Immanuel Randolph, with his counsel,
Harold S. Irwin, III, Esquire. Mother appeared pro se via the telephone.
3. The Honorable J. Wesley Oler, Jr. previously entered an Order on May 13,
2001 providing for shared legal custody, Mother having primary physical custody and
Father having periods of partial physical custody one week per month and six other
weeks during the year.
4. Mother lives in Delaware and Father has moved to North Carolina since
the previous Order was entered.
5. Father's position on custody is as follows: Father seeks shared legal and
shared physical custody on a month on/month off basis, which would reduce the travel
time for the child. Father also seeks a mid-point where the parties could meet to
exchange custody.
6. Mother's position on custody is as follows: Mother asserts that Father has
by verbal agreement of the parties been receiving two weeks every month and does not
believe a revised Order is necessary. Mother has transportation problems and does not
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agree to transport the child half way arguing that Father moved to North Carolina and
should be responsible for the majority of the travel.
7. The Conciliator recommends an Order in the form as attached scheduling
a Hearing and continuing the present Order with the addition of a shared transportation
provision. It is expec~ed that the Hearing will require one half day.
-=r - fer -0 -V
Date
~CP;.k /
cq line M. Verney, Esqui~
Custody Conciliator
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IMMANUEL RANDOLPH,
Plaintiff
v.
CRYSTAL R. RANDOLPH,
Defendant
IN THE COURT OF COMMON PLEAS OF
"CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -.: LAW
NO. 01-2383 CIVIL TERM
ORDER OF COURT
AND NOW, this 9th day of January, 2003, upon relation of Harold S. Irwin, III,
Esq., attorney for Plaintiff, that an agreement will be forthcoming in the above matter, the
hearing scheduled for December 18, 2002, is cancelled.
./ Harold S. Irwin, III, Esq.
35 East High Street
Carlisle, PA 17013
Attorney for Plaintiff
/Crystal R. Randolph
172 Loquitur Lane
Magnolia, DE 19962
Defendant, Pro Se
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BY THE COURT,
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IMMANUEL RANDOLPH,
Plaintiff
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: IN THE COURT OF COMMON PLEAS OF
: CUMBERLANDCOUNTY,PENNSYLVANIA
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: NO. 2001-2383 CIVIL TERM
: CIVIL ACTION - LAW
CRYSTAL R. RANDOLPH,
Defendant
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AND NOW, !hi, \,,16 my or I1A 7 ~ ,2001, "",}E
consideration of the attached Custody Conciliation eport, it is ordered and directed ni\
follows:
: IN CUSTODY
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ORDElR OF COURT
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1. The Father, Immanuel Randolph, and the Mother, Crystal R. Randolph,
shall have shared legal custody of Selena Carrie Randolph, born April 1 0, 1999. Each
parent shall have an equal right, to be exercised jointly with the other parent, to make all
major non-emergency decisions affecting the child's general well-being including, but
not limited to, all decisions regarding her health, education and religion.
2.
Mother shall have primary physical custody of the child.
3.
follows:
Father shall have periods of partial physical custody of the child as
a. The first week of every month beginning the first Friday of every
month, from 4:00 p.m. to the following Friday at 4:00 p.m.
b. In addition to the first week of every month, Father shall have the
following additional weeks:
I. One week from Friday to Friday, 4:00 p.m. to 4:00 p.m. over
Father's Day.
2. One week from Friday to Friday, 4:00 p.m. to 4:00 p.m. over
Thanksgiving Day.
3. One week from 7 days before Christmas Eve, at 4:00 p.m. to
Christmas Eve at 8:00 p.m.
4. One week in the month of January from Friday to Friday, 4:00
p.m. to 4:00 p.m. as Father selects. This week may be consecutive
to Father's first week in January.
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5. One week in the month of February from Friday to Friday, 4:00
p.m. to 4:00 p.m. as Father selects. This week may be consecutive
to Father's first week in February. "
6. In alternating years, one week from Friday to Friday, 4:00 p.m. to
4:00 p.m. over the Easter holiday. Father's week shall occur in
even numbered years.
7. Father shall have one week beginning Friday, May 18, 2001 at
4:00 p.m. to Friday May 25, 2001 at 4:00 p.m.
c. Such other times as the parties agree.
4. The parties shall share transportation, such that they will meet at the
Friendly's parking lot on Route 30 in Lancaster, Pennsylvania unless otherwise agreed by
the parties.
5. The parties shall keep each other advised immediately relative to any
medical care or medical emergencies concerning the child and shall further take any
necessary steps to ensure that the health and well being of the child is protected. During
such illness or medical emergency, both parents shall have the right to visit the child as
often as he/she desires consistent with the proper medical care of the child.
6. Neither parent shall do anything which may estrange the child from the
other party, or injure the opinion of the child as to the other party, or which may hamper
the free and natural development of the child's love or affection for the other party.
7. This Order is entered pursuant to an agreement of the parties at a Custody
Conciliation conference. The parties may modify the provisions of this Order by mutual
consent. In the absence of mutual consent, the terms of this Order shall control.
BY THE COURT,
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cc: Harold S. Irwin, III, Esquire - Counsel for Father
Joan Carey, Esquire - Counsel for Mother
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IMMANUEL RANDOLPH,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,PENNSYLV ANIA
V.
: 2001-2383 CIVIL TERM
: CIVIL ACTION - LAW
CRYSTAL R. RANDOLPH,
Defendant
: IN CUSTODY
PRIOR JUDGE: None
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the lll1dersigned 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
Selena Carrie Randolph
April 10, 1999 Mother
2. A Conciliation Conference was held in this matter on May 9, 2001.
Father, Immanuel Randolph, was present with counsel, Harold S. Irwin, III, Esquire, and
Mother, Crystal R. Randolph, was present with cOlll1sel, Joan Carey, Esquire.
3.
The parties agreed to an Order in the form attached.
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Date
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Custody Conciliator
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