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Home My WebLink About01-2502 FX j" -\Jr_r __ '" , ~--. ~ = "- "-':~; ~;;';,~~IP -,',,-,~-- , . . . . ., . . IN THE: COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . NICHOLE M, CUTLIP, . . Plaintiff VERSUS ROBERT L. CUTLIP, III, Defendant . STATE OF PENNA. No. 2001-2502 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE . . DECREE IN DIVORCE . ~7 J /:'1I:ftl4. 2001 ,IT IS ORDERED AND AND NOW, DECREED THAT NICHOLE M. CUTLIP , PLAINTIFF, AND ROBERT L. CUTLIP, III , 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; The Marriage Settlement Agreement dated July 16, 2001 and signed by the . parties is hereby incorporated into this Decree, but not mer ed, . . . . . :t::t: ",:f. . . '-1'< 'II ':. _to ,r . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . illr ,0,,,, >C,.,,/,;;,~, ;;.-': .- "'"(""'" .'1' 1 ,~- ". :~,~ '~~i1llill~~w-.,L*'/.~.'1_..;m;,I";jj;j.~_~-' "~ "f",< .. , os .. ~ , , - ,,",,,,,,,,i- "- ",'0< ,'~:"f.~ili;k "~""-'-" .". - ' , ",i . 'IA.. , ". .f , J ~', r"~"_ ~ f'''' ~.,! '}~, t\ ~~tJ( W-C'~~ ;#4/#~ ?1f;C}/ '7f~ ~ Z ~' l\l!k;,I,"HJLLJ. !~J .. JI.:iiII!!lI.LL-<L~~gi,,,,U,,w",",~~""""~ ".- ~.. ^- JI cq ..g> '" " NlCHOLE M, CUTLIP, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, CML ACTION - LAW DI . ~S"O:e CllVIL TERM ROBERT L. CUTLIP, m, Defendant IN DIVORCE NOTICE Yau 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 wamed that if you fail to do so, the case may proceed without you and a decree in divorce or armulment 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, DMSION 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 TmS 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, Pennsylvania 17013 717-249-3166 1-800-990-9108 "'!~l!ll>, , -,<~~ .';'~'i'- _",c,,,-_,,,,", -' ~ .", _, ~,,~ '~-__sl~k_.T-_'" '''. "_"'" co" ,,_w_._ _= 'T-r ~,,___o_.., , . r "--"l 'H) , , " _, ,~.'" ,_ _ .. _ ,_ ,_,. ,,~ , ~" "'",'1""" " .. AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Conunon 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 acconunodations 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. ._ ~,.7,""'"'<?""",____:>", ._ "'-"_~-'-'-,'I,-..I____I',-'_-'" ~'____'''_'" ~.,-jT"""_ . ., __, -~',,^,.~ '--,'__'_~___~ ,," -. ~ .. ~ NICHOLE M, CUTLIP, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW . ; "JL",ol- ;'S'Q'v CIVIL TERM ROBERT L. CUTLIP, III, Defendant IN DIVORCE COMPLAINT ~ DIVORCE PURSUANT TO SECTION 3301(c) OF I!!]j; DIVORCE CODE NOW comes the plaintiff, Nichole M, Cutlip, by her attorney, Marcus A. McKnight, ill, Esquire, and files this Complaint in Divorce against the defendant, Robert 1. Cutlip, ill, representing as follows: 1. The plaintiff is Nichole M, Cutlip, an adult individual residing at 101 Spur Road, Carlisle, Cumberland County, Pennsylvania 17013, 2. The defendant is Robert 1. Cutlip, ill, an adult individual residing at 1141 Longs Gap Road, Carlisle, Cumberland County, Pennsylvania 17013, 3, The plaintiff has been a resident of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce, 4. The plaintiff and the defendant were married on June 26, 1999. r~mJ", -.. '_'_'. ";0 '"_,,_, ~~" _ ,~.,'M 'T. ~_, ,:'__~",I!!lIl, ~ _,,""_,,_'__~ ~,"" '0" ~,~, ""'_"~C,_,~_",o" n', ," _". or _~ <,,~, "",-,~ , . ,. , ,- ~, 5, There have been no prior actions of divorce or for annulment between the parties, 6, 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, 7, The plaintiff avers that she 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, Respectfully submitted, By: Date: April 27, 2001 :']:"1.,...,.,. \-,,, ^"" .-~ "-~ d,,,",,", _ ,,____ ~,--JWI_";f __~ _ ,', ,"~,""="'_ _"__'-'_'I__,___~_ '., "._ ~ ." _;_,C~" ~_ __~~. _" , .,,~"o_, "_, _ - ~ ." -- -~--, VERIFICATION The foregoing Complaint in Divorce is based upon information which has been gathered by counsel and myself in the preparation of this action, I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa, C.S,A. Section 4904, relating to unsworn falsification to authorities, Date: April 27, 2001 ".'_'.e '~",- <,'0' "'_"~, ,,';'-'/"". n-'~-I"-"~_'_'" " q"~= -.-Y,...,__ Ie 'I. .,., "_ .. " ,. " ,~, ~~," ~'. - "~ NICHOLE M, CUTLIP, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW ;-n.,. DI- :<$'b.:b.. CIVIL TERM ROBERT L. CUTLIP, III, Defendant IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: I. 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. 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, Date: April 27, 2001 -',~ - '-_<F'"~,~'~_"""___,,, on'')'' - _,~,___) -'~_"I";'-I_"'if""__" ,~~__. '_~''''''''''"'''' ",_"O~_"'_""'._'r _ -,'_ ..A _, _ ~ "~"d ,. - 'II e,t; V\t ,:~,-, - --, . -~ ~ " _e'!!~'1 (:) ~i - - o ~ (j , -- ~ - ..() - 6' ---- ~ ~ ~~ ~&~ ;J:) , f~ $ "'_'.'>O"""~ '"'-";'_' .,"' ,,~_~~,~,." o c 2~ "'7~' 0)); -,?. kG PC"> 2(5 )>c z :<! 'h "~'ir~-'"' .~ o c; ~n :-:-::i :i> -0 ;0 r" -.l C:l:~Q '--:';0 1") 1... :::,"" ,..." -'"" ~ ~~?, ~ -~ ".t'''- ~ -0 -7!'" w '-11 '0 _~~l_IJ-,'I!!l_JJIl ~!;ll!~_____,_, " ,_,_,~, i~"-~~ (l-.,ft!; _ rl1lJ - . NICHOLE M. CUTLIP, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - LAW 2001-2502 CIVIL TERM ROBERT L. CUTLIP, III, Defendant IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA, R.C.P. RULE NO. 1920.4 (a)(1)(O COMMONWEALTH OF PENNSYLVANIA : SS: COUNTY OF CUMBERLAND NOW, Marcus A. McKnight, 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 captioned action in divorce. 2. That a certified copy of the Complaint in Divorce was served upon the defendant, Robert 1. Cutlip, ill, on May 16, 2001, by certified, restricted delivery mail, addressed to him at 1141 Longs Gap Road, Carlisle, Pennsylvania 17013, with Return Receipt Number 7099 3400 001849971803, 3. That the said receipt for certified mail is signed and attached hereto and made a part hereof. Date: May 17, ~001 , , ',' ~ '"""",I'l"'I_ "1',..-.. ." ~.- - - ~ ,.,.' "_,__,0'", . .. ,~y ." " , ~ - . ~... - , . - " ~ ".... .,.. U.S. Postal Service " 1 ' !! CERTIFIED MAIL RECEIPT :.r! (Domestic Mail Only; No Insurance CoVerage Provided) . . l fT1 Cl "" .... NICHOLE "" 0- 0- =r car/moo Fee "" r'l Cl Cl Return Receipt Fee (EndorsemenLBequired) Restricted Delivery F (Endorsement Requir _ .f'ostmati< ",'" :3 aD Total Postage & FeeS $ 7. 1.; Cl Cl .=r Recipient's Name (Plaase Print creatly) (to b,j- compreted by maner) I'T1 .mt."_RgBERl'..~n~:LJI_,_JJJ~.~...nnn...m_nm_n....~_~._..mn: 0- 'i."I1i fP'tfufGS' "1M> ROAD 1 0- . I Cl -eam;;:rsI,E"PA:..t'7(H3""'" '......---.--..--...-..-.................'~... "" 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 mailpiece, or on the front if space permits. 1. Article Addressed to: )t- D. Is delivery address different from item 17 If YES, enter delivery address below: HR ROBERT L CUTLIP III U41 LONGS GAP ROAD CARLISLE PA 17013 3. Service Type g:g Certifjed Mall o Registered red Mail o Express Mail lJi Return Receipt for MerchandJse _ o 4. Restricted Delivery? (Extra Fee) iXI Yes 2. Artlcle Number (Copy frbin'servfc..e labeJ) 7099 3400 0018 4997 1803 PSForm 3811, July 1999 Domestic Return Receipt 1025SS.OQ-M-0952 Ejlj ltS-J !""', , ,~ ,rl ':':.' "'~"'~ ~-""" ~ Co _ ~ ~," ~_ ~. ~.-- -, ,,",,,-'.,,, -"'-'~' ."_J; "J _ ",_>,,~"_ ~- ~ ~(") ""0 Pc: Z =< ~""""~,_",,r_ r .lIl'JI!.)]lJ1~, " ;<.;~ i-W,>"''''-'~,*l-ir 'J'..~ "'1' ' "'._". (,. . ".., i,,_' ';'.:- & - c' '--'-->_J:'~i):r__-,..-l "_ .- -"." ',ej,,' , :ii " 'I II !I , ,Ii ,I ,I !I 'I II , I:-~-~'='" , , NICHOLE M. CUTLIP, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - LAW 2001-2502 CIVIL TERM ROBERT L. CUTLIP, III, Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT I. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on April 27,2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the complaint. 3. I consent to the entry of a final decree in divorce. 4, 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, 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 authorities. Date: July 27, 2001 '-,'---"',,--- ,.-"o-"---~r!I".'_,_-, '~"'i" >."f"-",";;'""",',"'" ,~" ", ". d""~__'l _,-'-~",~, ~,'-_", ." ,."."" , ".. ,~ ^,. - NICHOLE M. CUTLIP, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - LAW 2001-2502 CML TERM ROBERT L. CUTLIP, III, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I, 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 inunediately 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 made are subject to the penalties of 18 Pa. C,S. Section 4904 relating to unsworn falsification to authorities, Date: July 27, 2001 .,~~- .' "-.' ".. ,,'"" "~fc' _ "-'~_, > '''_'_.,~_F_"""~~<,<','I'fflI.".,, _.__"~, , ' ,,' _~,""__ "~""~d_ _' ""_~_~ .,. Vo r;-<",~ "'__'__'._~_' ',~,~-_,~~' ,__ _-"__,,~,,' _., ",__~,__, --" ---=~ -- NICHOLE M, CUTLIP, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - LAW 2001-2502 CIVIL TERM ROBERT L. CUTLIP, III, Defendant IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed April 27, 2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the complaint. 3, I consent to the entry of a final decree in divorce. 4. 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, 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 authorities. Date: 7-3( .2001 Ztd-XC#fTIA ROBERT L. CUTLIP, III Defendant i~, """" __ 'H" ~ - - -, ;'-~". ',,"~ I,'k-,""/t:,;",_-~, ~, Y--', " . ';-'" ,,",-' -_."'.:,~.-l''';',-:".,~,~~,,,_,~, ,~ ,"', ,~", ,-, -" . j--c ,0- -~,,--" ----~- :r" l " '".- "-""''''-~,,^ ',,;)'_, "_oc" _,_,< ~, ~, ',." ." e,~<' c_, -~ [ - ,,,~ -'p,,", '-";&r,o-,--.T~-iQj'i'-" __r~~';!L_ 'r.lllt,Ullll,r ','r>,'-",.>.,' ,<'~J"-i+'t'j~'h~nt-\Jf7~f1~},+Y~ ' '.;-l"f,.;;~tr-r-'-..:-_: u 111 _ ~ () c:' c:: s:: ):.. :-"j "Ow c: (DfT1 G:> .";,,-..:: .z: .-~, ",f-r: -~.. J Zc cD v. f\,> _ J ~::! '''';;-- ~~ ~~~ ;;$0 -0 :g ~.~- -r, ZO -, ;~...::;~; -0 s-:) iSrfi Pc:: Z :..> :.t:;j =< ::0 (J1 -< ,. -'~ L___,,_,~ o,~ ""[":'1.."- ",7 >_,_~;""_~ NICHOLE M, CUTLIP, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - LAW 2001-2502 CIVIL TERM ROBERT L. CUTLIP, III, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I, 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 inunediately 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 made are subject to the penalties of 18 Pa, C.S. Section 4904 relating to unsworn falsification to authorities, Date: July 31, 2001 2?--t- i C.fk V.' ROBERT L. CUTLIP, I Defendant , n ,~~ .~_..<_..",,,---,,,,-, -, , -",--; -,^':- ,_?_",:,,_~~)j~I~I_y.'A"'O_~'" 7,'.,_~_,,~, "'c' ., --'~\'~' :~~',- ,I - ~~, 1'''''''< - - . -' ,~..-_L", _ ,_ ___' ., ,,'''C''" -, _"'>_-~ ""~~_,__; r ". ~", 'h ,,"_.', . ~ _ ,., <"'~ _,~, ,'",,~ ' ~. .". " ~ ~)~ '" "'''''~- ~ -,.~ '" , -~..- ~_. -,,'''''' .. '''-''''-'''''_~r''e''i'!ft~n ~-1Il!":lb~ ~; ~,~,..t~ ;L 0 c. (-~ C '-,'\ -~ ~ "" "'U 0: ~ mn"'! (i') -- Z::J: I (T\ &~ r--) N T -<..::~ ~~;) ~C :2 :..7~ :;ti ~8 _'ho ~:M ~c C:? u ._-j ~ ",) "'", :n (J1 -.:; ,_n~ ---X,., ~ ,,- ~J~~f ' -.~ .-"," : IN THE COURT OF COMMON PLEAS OF NICHOLE M, CUTLIP, Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - LAW 2001-2502 CIVIL TERM ROBERT L. CUTLIP, III, Defendant IN DIVORCE DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, 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. 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, Date: 7- '> ( .2001 f2~cl- ~:JZP ROBERT L. CUTLIP, III Defendant "'-~ '-~-"- - ~ ,--. <,',''',,,,, - I!'I"'.-.-"", "",--.,-.- ,"''''!--"' "0-1 e'" ,,"_ ,0, '~", -.n_, " ,~ __ ,', ^ ~ . >-L' ',-,- WI "~ ~ _,~" > _^, ,0" "','_ -" --,--,' . .~"- ,,== "".. > "~~",,,,~ '.,,' . .. 'V ,_~"~ ~ ~," - -~ '__'7,~~IW"'I'<,l....,}~ .""ij,,~~ ~~ ~ ",.......1-1"' " .. I I -. 'J"""''''~' ''''^''''_'-r~rf''t'f# () ~ -OCt:! g:! [1~ Z.:r-: we- -~~. ~..?- ~l~1 Z("') ::;:;:0 !;:.: .c: =< '':7' ~",}l,.,4i;, ,', -', c..~ ("'" -'! """ - - Ci'> I ^', r. ,- ;~_;~;l5 ='" ;,?~] ~ :n ~~ ~J."_ ~~ :." (J"t ,.r-,.__ O_}"_'__"~_. _j',,;, NICHOLE M, CUTLIP, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - LAW 2001-2502 CIVIL TERM ROBERT L. CUTLIP, III, Defendant IN CUSTODY ORDER OF COURT AND NOW, this ~-A day of ~. 2001, upon consideration of the attached Stipulation, custody of the minor children, MADISON M. CUTLIP, born March 7, 2000, and MIKENNA M, CUTLIP, born March 7, 2000, is as follows: l. The mother, Nichole M, Cutlip, will have legal custody of the above named children. 2, The mother, Nichole M, Cutlip, will have primary physical custody of the minor children, 3, The father, Robert 1. Cutlip, III, will have supervised visitation once a week of the m~'n children as the parties agree is in the best interest of the children, , ~~ C~'I).: J, '-'," """"0- <:I~_" __~_-'.<" 0'""" '_'.,,""'_ '~'_I_"_I-_'" ',_"':" ',_,,_ ,,_," ,,,,,",,___,_,~,",", ~'_.,"_ ~ I ~"" ~ ", ,~Y '_',_ ." ~_,Jl'L_", 'II1N'i^1ASNN3d IJNf\OO Oi\!\/l'tF18V'4n8 8S:Z1\M Z-SrWIO I ,,~I '0"""\-1' I' ,'" ^O'J.L 1'1'J.l."'jl.'..- 38\1.;Cr-CJ\_\;i ,,~,o_. - " '. _,""""",,l'", ' ~, _~_C_H"~"~ _"",,- "i' ... .-. ,,>--- """.,,'"<~ -'~~:~~ , " ,'_ \ " ~ ",-,~"",,~lt _ J_ ruUil II [ , :~7~"-':,"-<'--"I'Y'lri; ','_ ,_~""",,,,,,lt_,., ~"..~C',~k.,..,,,~~ -' ;lfJI,!;)-. ,{",,,,J . NICHOLE M, CUTLIP, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - LAW 2001-2502 CIVIL TERM ROBERT L, CUTLIP, III, Defendant IN CUSTODY CUSTODY STIPULATION ~ AND NOW, this~ day of 8'-' Q.{F' 2001, the parties, NICHOLE M. CUTLIP and ROBERT L. CUTLIP, III, hereby enter into the following Custody Stipulation regarding their minor children: l. The natural mother is Nichole M. Cutlip, an adult individual who resides at 101 Spur Road, Carlisle, Pennsylvania 17013. 2. The natural father is Robert 1. Cutlip, Ill, an adult individual residing at 1141 Longs Gap Road, Carlisle, Pennsylvania 17013. 3. The parties are the parents of Madison M. Cutlip, born March 7, 2000, and Mikenna M, Cutlip, born March 7, 2000, 2 .'c;h-. ':"".':;:,,-r,-,e-^ ''''''',,' ',_''''''''",; ",~.,!,':;__"_"'__' ,~.I:'1I~r'i'''~' ","'~,,~_." ",,,_~,_,", "1o,)-~'r'~'- <,"1"'''''' '_," "_,._ <-..--_"'_"_~'''',_f_^. ~',_._ ~'-~,."" - - ' - 4. The mother, Nichole M. Cutlip, will have legal custody of the above named children. 5 The mother, Nichole M. Cutlip, will have primary physical custody of the minor children. 6. The father, Robert 1. Cutlip, III, will have periods of supervised visitation once a week of the minor children as the parties agree is in the best interest of the children, Intending to be legally bound, the parties enter their hands and seals the date first set forth above, ) R~ i. ~ yP:(SEAL) ROBERT L. CUTLIP, ill 3 -: ~-, - "'~- y<~,'~";"',,,''''C:..,.'T-,- ,-",'~- ,., -".j '" -""''''Ii'''I~i """_~'_ ,"" ._' -_~,"", o,''''~r.-l , --rr'-,~ I,,' q "., - -- _'"'~ ,'-I-- ',-,,_ <.. ,.. ."_ n.,', ,~ -' , . "","",,-'-" .-". -"~ ." .-?- !li ~~ 1"'1'"' , - " ~, 'h..r"<>' r'1'l'"_:,_' ~, - ~ ~^ ,~ - -" -, >'~ '" " "~"~ - ~-~ ~." " -~-~, ',"_'- ~-""'<b"--"'~'__' "_--'",.~"",..." 1IIii1~ 'fill T r '""11 rar . f-T"""l!!lIffl"~fi'~~l1'MI~~l>_\l~:~~_i~_' ,.!,.'__~_ 'fF-~ NICOLE M, CUTLIP Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, NO. 2001-2502 Civil Term ROBERT 1. CUTLIP, III Defendant CIVIL ACTION - Custody CERTIFICATE OF SERVICE I, Henry W. VanEck, Esquire, hereby certify that on this day, a true and correct copy of the Petition for Modification of Custody Order was served by first-class mail, postage prepared, on the following: Marcus A. McKnight, III, Esquire Irwin McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013-3222 CUNNINGHAM & CHERNICOFF, P.C. Dated: March 29, 2002 &k- By: Henry W, an Eck, Esquire 2320 North Second Street P.O, Box 60457 Harrisburg, PA 17106-0457 Telephone: (717) 238-6570 -'1""l""l"" -~ , - 1'-- "-,~ -__._II"I,~;"~_~__"q,,,r_," ,. ',.' ,'" - '1', -', 1__~ , PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NICOLE M, CUTLIP v. 01-2502 C1VILACTIONLAW ROBERT L. CUTLIP, III DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, April 02, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawu S. Suuday, Esq. , the conciliator, at 39 WestMaiuStreet, Mechanicsburg,PA 17055 on Thursday, May 02, 2002 at 8:30 AM 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 TIffi COURT, By: Isl Dawn S. Sunday. Esq. ~ 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 YOURATIORNEY AT ONCE. IF YOU DO NOT HAVE AN ATIORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIffi 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 <"f'lIll'lfi![ . ~l I I ' ~ ., , '0 j~O," ;.{~,....,..l'4lli!kjill:I<:J'hi%~0.",i:!i'M<M'_1;'t"~,,,,,j,"'i'.)_\ii'd!,,"~L ,',,_J-;,,"h_:~'"'"""I~"',"I';",!<--,V";_&h,d"''''i>,K~J!&lk'iiil.~";O:'t1iW-Ol,""'il."t__~'ill!llill'liHl"!!tI!'hi$~~~&!~.i.'m~W4iJj~~"" ~~_-,-_, ~ F\\~9:.S-\\~~rO\f>p,'( 0... "1"'\ \t \~.,."" 11 ,.....'\. \~ \ \r~_~ 1 ,\'". ' OH?R -3 PI1 3: 38 C\JMBr.R\..AND CNO\~\~ P8'lNS'fL\lP\ " c /j-JtJ.;( dvI.. ~ m~~ 4' ~ ~~f"CI:J ~ .~~ i# fttC~ ~ ~"J-O.,.l ~~~~~ - ,),~L. U ~JLJ~!LJ_,..o1~""., ~".,"'.,_,~_""~,," ,,,,~~',,''''7''~'''''". '_.,', '-I _'.-" __'~'_" ","''' ".A ~.~ -. -- ' !if;! , , NICOLE M, CUTLIP Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL V ANlA v, NO, 2001-2502 Civil Term ROBERT 1. CUTLIP, III Defendant CIVIL ACTION - Custody PETITION FOR MODIFICATION OF CUSTODY ORDER 1, The Plaintiff is Robert 1. Cutlip, III, residing at 1141 Longs Gap Road, Carlisle, Cumberland County, Pennsylvania, 2, The Defendant is Nicole M, Cutlip, residing at 101 Spur Road, Carlisle, Cumberland County, Pennsylvania, 3. The Plaintiff seeks partial custody and visitation of the following children: NAME PRESENT RESIDENCE AGE Madison M, Cutlip 101 Spur Road Carlisle, P A 17013 18 months Mikenna M, Cutlip 101 Spur Road 18 months The children were not born out of wedlock. The children are presently in the custody of Nicole M. Cutlip, who resides at 101 Spur Road, Carlisle, Cumberland County, Pennsylvania, "'~~""""~'I' . ";;." , '-,' ", ,--' ,'- " , 0/.","" ,_ _ _~"I""I':, ,_,'\'~<"",~._ e,. ' _ " -,'r , < ~ , .,> "' _ __c_ , During the past five (5) years, the children had resided with the following persons and at the following addresses: Robert 1. Cutlip, III Nicole M, Cutlip 10 I Spur Road Carlisle, P A 17013 The mother of the children is Nicole M, Cutlip currently residing at 101 Spur Road, Carlisle, Cumberland County, Pennsylvania, She is currently divorced, The father of the children is Robert 1. Cutlip, III, currently residing at 1141 Longs Gap Road, Carlisle, Cumberland County, Pennsylvania, 4. The relationship of Plaintiff to the children is that offather, The Plaintiff currently resides with the following persons: NAME RELATIONSHIP no one 5, The relationship of Defendant to the children is that of mother, The Defendant currently resides with the following person: NAME RELATIONSHIP Saumual Knisely Father of Defendant Roxane Knisely Mother of Defendant 2 \~,'~ ~ -'.' ._; ".-' "~"_,_,,,,, --',U-'" ,"'_"..__~~'''''_ '," ',' ': '1~1~"_o__ -_' ;~" ,,_'cu_ ", '-~"-I . I '- . ,-- ""'" .,... . ~-':' ,',- ,- , - '. '-,-" , , . 6, Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another Court, Plaintiff has no information of a custody proceeding concerning the children pending in a Court of this Commonwealth, Plaintiff does not know of a person not a party to these proceedings who has physical custody of the children or claims to have custody or visitation right with respect to the children, 7, The best interest and permanent welfare of the children will be served by granting the relief requested because the children have come to know their father as a constant source of love and affection, The Plaintiff is capable of providing the children with a stable environment better suited to the raising of children then that which is provided by the Defendant. 8, Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the children have been given notice of the pendency of this action and the right to intervene: 3 ,- -~,. " ", ~,..,-~".,.. -"I""I-~,~'~ ~ ,,,,--~-~,;,,,-- ^ '~I"- ";' - I' 1" ,-- _r.", .7" ~ - . , " WHEREFORE, Plaintiff requests the Court to grant Custody-Partial custody- visitation ofthe children, Respectfully submitted, CUNNINGHAM & CHERNICOFF, P,C. Date: 1;/:27/6')- W.UUA.- By: Henry W, an Eck, Esquire I.D, #83087 2320 North Second Street P,O, Box 60457 Harrisburg, PA 17106-0457 (717) 238-6570 4 ~" " '-I" ~- , I~I "O._'O~ _ ", _c ~-'i"'" - r_'" _ "" ,~, , ,-.- . VERIFICATION I, Robert 1. Cutlip, III, verify that the statements made in the foregoing Petition for Modification of Custody Order are true and correct to the best of my knowledge, information and belief, I understand that false statements herein are made subject to the penalties of 18 Pa, C.S,A. Section 4904, relating to unsworn falsification to authorities, ~ 71.. f?...bf... -:;T7F Robert 1. Cutlip, III , Date: 3- ~'( - 0.:1. : """"'ff""'-P --,'1' I~'''I' ' : -'-1'1, _ ..1I!imf Ui ~ ~ ,,..,.~ _" ....,,,,,,,,,,M ~"r. ^" = _~" '._<" """.. - "'. I 1riiln.< '~Ct . 1- ~ <l : .. & J r ., -'.,J --- ~ 8 . . ~ ; )J ',; t c. J."~;2 '. ~ 1 "'~. ~~.-' ,~jl <i .-:;:, _.~ , 0, ,~:) -"<( ~ ~ ~ Wjlllllmo ,~~ 1flffi'!1'~'~__~l'j~~Il~~IJlf11''l1lIi!i'':H~f:''l)f'''8'''"''''-'-h'"f-,-_c;"",,''';;''r,';';:.U"~""_"-'-',fl{Of;;F"",,""'-'<TY!""_'rt"';~~f."'t,lIWWJ1li\!l<fu';I'''!ii:);11!~~~~ NICHOLE M. (CUTLIP) HALE PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 01-2502 CIVIL ACTION LAW ROBERT L. CUTLIP, III DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, July 30, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Suuday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, A"2ust 26, 2003 at 8:30 AM 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 defme 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 Abnse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl Dawn S. Sunday, Esq. Custody Conciliator u 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 -*~- . . -~ 111 - :,cd"'. .; ~ll'ii:ltlJ1HiIIl~~MJ.i."q-<:j;'f.E~lv<1<ilW'!4."":";M6'~i*,""';t(:",o<","" ."", .,,,~-.,,,<ii ';"j,~-;..'''-' ,,,,_ 7.31.03 7.:JtY.t2J 7-JI/ . .v M/;,'.j/!J;,lil!liliIIU'c,VllllJ U!MU.mll.. ..~. tb"\,,,.",~'"H"""" ;.'''-.'''tBk:,<t.I.~j..lf,,(;a.-ti;i/jjl!~~''''~i!l:~~.;~~~UilllllJilj~ .,,-,~ x l'il FI')-()~PJ'E 'l.._.1 ,-. ~v OF TI-":: :.,,,r:'" :r1'iDTI'RY ",I.- , ,:-__, ; ,,-, I,"" ("'I, 03 JlJL 30 rl'i 2: 1.5 CUM8tHU.~:'~G L~Uul~T'( PENNSYLVANiA &p. ~ ~ ~ d7f.' /U~ 7t~, -Jb ~ 4~~ {~ ~ -zb q-~ "",' -'"'~- .-'-'" - ......~'bllliidiP"'" ~- - -c ..-; ~9- .!jj <~~~,~ ., NICHOLE M. CUTLIP, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 01-2502 CIVIL ACTION LAW ROBERT L. CUTLIP, III, Defendant IN CUSTODY ORDER OF COURT AND NOW, this ~,~ day of Iv1 ~ ' 2002, upon consideration of the attached Custody Conciliation Report, it IS ordered and directed as follows: L The prior Order of this Court dated August 2, 2001 is modified to the extent of any inconsistencies with this Order. 2. The Father shall have physical custody of the Children in accordance with the following progressive schedule: A. On Sunday, May 19, 2002, and Sunday, May 26, 2002, the Father shall have supervised custody ofthe Children at his residence from 1 :00 p.m. until 4:00 p.m. B. On Sunday, June 2, 2002 and Sunday, June 9, 2002, the Father shall have periods of custody with the Children from 1:00 p.m. until 5:00 p.m., which shall be supervised for the first two hours and unsupervised for the second two hours each day. C. Beginning on Sunday, June I6, 2002, and continuing, pending the second Custody Conciliation Conference, the Father shall have unsupervised partial physical custody of the Children every Sunday from I :00 p.m. until 7:00 p.m. 3. The parties shall be cooperative and flexible in making any necessary changes to the custody arrangements to promote the Children's adjustment to the schedule. 4. The Father shall ensure that the paternal grandparents are not present for periods of supervised custody. 5. The Mother shall provide transportation for all exchanges of custody, unless otherwise agreed between the parties. r I ~~,~~ 6. The Father shall refrain from drinking alcoholic beverages during his periods of custody. 7. The parties and counsel shall attend a second Custody Conciliation Conference in the office of the Conciliator, Dawn S. Sunday, on Tuesday, July 23, 2002 at 8:30 a.m. The purpose of the Conference shall be to review the Children's adjustment to the gradually increasing partial custody schedule and establish ongoing custody arrangements. 8. The parties shall be supportive of each other's parenting relationship with the Children and shall encourage the Children's love and respect for the other parent. Neither party shall do or say anything which may estrange the Child from the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Child comply with this provision. 9. 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 ofthis Order shall control. Edward E. Guido, J. cc: Marcus A. McKnight, III, Esquire - Counsel for Mother .ftIenry W. Van Eck, Esquire - Counsel for Father '7 t~ .!J-;U.-OA 3,""'''~,,, ~ -~ 1'1. " -' ~~-'\.,~~''''' !l11 f."_.~" "~1l!I!lIII!I ~~ ,~~ '_~CqM' ~-.' ~ .", ..U]mrmliJii "N'n~~g:r\l:\S;\JN:Jd /\..Lt- jl'" n.''',../'''"71''''\_ .,.r,..- ,,', ,. '.,'..'",."'f~,., ~ -" 'j-,nr Iv 91 '['1 'ii' "j :-,./ 7, ! '''i"' L' c.. 1\ ~~~. ,.. II "f '~l,' /.1:-11//"-'1-: " '_V', ~ 1I1ll!111l4 I ~, ,1 ~1",,~,,:,_ ., ~~,,,,,,,,,,~~,,..,_,_t ,~MJ;;~~~'iiji)lii~'\lil'iR'''P;;;:'''''-i<>''t;fr'''~F~',~~~F!''''_aH~ifi('@~fif"*'*~!\""~~ft'@1f~~~j"i%igli~~~Jf~'''''''f~~,,;_,_,lI\~~~ NlCHOLE M. CUTLIP, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 01-2502 CNIL ACTION LAW ROBERT L. CUTLIP, III Defendant IN CUSTODY PRIOR JUDGE: Edward E. Guido 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 Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Madison M. Cutlip Mikenna M. Cutlip March 7, 2000 March 7, 2000 Mother Mother 2. A Conciliation Conference was held on May 14, 2002, with the following individuals in attendance: The Mother, Nichole M. Cutlip, with her counsel, Marcus A. McKnight, III, Esquire, and the Father, Robert L. Cutlip, III, with his counsel, Hemy W. Van Eck, Esquire. ~ I.?f r~W(T Date 3. The parties agreed to entry of an Order in the form as attached. D~ Custody Conciliator "-,~"",",," . '" II ~~. ,~~ ,~~~, Tn -. ~ , NlCHOLE M. CUTLIP, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 01-2502 CIVIL ACTION LAW ROBERT L. CUTLIP, III, Defendant IN CUSTODY ORDER OF COURT AND NOW, this ~ day of ~ ' 2002, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Orders of this Court are vacated and replaced with this Order, with the exception of the August 2, 2001 Order which is modified to the extent of any inconsistencies with this Order. 2. The parties shall obtain an assessment to be perfoimed by Georgi Anderson, LCSW, ACSW or other professional selected by agreement. The purpose of the assessment shall be to evaluate the Childrens' readiness to expand the partial custody schedule to overnight periods. The parties shall also obtain recommendations concerning implementation of an expanded schedule which will best serve the interests of the Children if appropriate in the opinion of the professional. The parties shall equally share all costs of the assessment. The parties shall cooperate in schedulrng sessions for the Children and the parties as promptly as possible. 3. Pending receipt of the professional recommendations and subsequent agreement of the parties or Order of Court, the Father shall have partial physical custody of the Children every Sunday from 12:30 p.m. through 7:00 p.m. and on alternating Saturdays from 9:00 a.m. until 5:00 p.m. The alternating Saturday periods of custody shall begin on August 10, 2002. 4. The parties shall be supportive of each other's parenting relationship with the Children and shall encourage the Children's love and respect for the other parent. Neither party shall do or say anything which may estrange the Children from the other parent, injure the opinion of the Children as to the other parent, or hamper the free and natural development of the Children's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Children comply with this provision. -Y""'1'l''''!<lSi"-~I'~1 I~I -II I [ r== -, . 5. Upon completion of the assessment and receipt of the professional recommendations, counsel for either party may contact the Conciliator to schedule an additional Custody Conciliation Conference if necessary at that time. 6. 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 ofthis Order shall control. Edward E. Guido, J. cc:....Marcus A. McKnight, ill, Esquire - Counsel for Mother 7 }Ienry w. VanEck, Esquire - Counsel for Father to-p-U.c ~Oj t 1- g-ct-OJ. l R~5 ~- r~'1 ~ - '" '~"".Y .1"'"''ii';tlf"'JJ'''tt''iilf1 ".lill'tlllnrifllflfl t1'trnl,'~tiiif'ijl1l',~:tl VlNVi\II\SN~.~~, )Jj,If"',\rl n\'\'r~t~-jrl!r~no \II ~..,.~ is:Ol\W - (.el" 70 I:) - JI . ,.. ^tN1Ck\C, ;-;:': ~)sd-,- -~',,;-; ""1(l'IJ,,{l, t-t 1"1 \;:-.\ :J-.J...J_v ... :.0 ~. ~ -~,-,'<' ~_.~ - ~~ ~,,~~ ''" - --~ _ ,~~W;~i<;'_~_c"';-'I""'Y."'~",,,,~,~ <"'o,"'li,~_<11'''''i'''~1~,rc[f''t~'W~~i]iffi''l<l;i'llf'~!lm!f,i~f~~f~':, . NICHOLE M. CUTLIP, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 01-2502 CIVIL ACTION LAW ROBERT L. CUTLIP, III Defendant IN CUSTODY PRIOR JUDGE: Edward E. Guido CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 19I5.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Madison M. Cutlip Mikenna M. Cutlip March 7,2000 March 7, 2000 Mother Mother 2. A Conciliation Conference was held on July 30, 2002, with the following individuals in attendance: The Mother, Nichole M. Cutlip, with her counsel, Marcus A. McKnight, III, Esquire, and the Father, Robert L. Cutlip, III, with his counsel, Henry W. Van Eck, Esquire. 3. The parties agreed to entry of an Order in the form as attached. Date cl7 301 ;>d0a- (OMU. J~~ Dawn S. Sunday, EsqUIre Custody Conciliator '^-'~-'""""'""f"'" -'"'. ~ 1'1""1 " - .,.-< <_. -",,,,,,;-'~'~',4<'-'::;-,.'_'~'''~~-~'' 0_""'" ,"'" ~ "'!OM _ .'" IJl. -=Nm!ll~)L.,!liI~ <"" ~ - ""'., .,C. 'llTn': .C"{"'!"''J''i11'ili1fj'~:\V~''fJI~.~~t',1!'lmr'1liiRiiiiT'ii~' '.'\.i"~""l!i" o. '1"""'!i'!I _~J~~"fi@:~;",:,,"P-__W-~F"1~':"""_"-.-'_':J:1n',"_"'E'"!:'ii',i\FJl!!Y~iW;~';1<Jtj.j,",,"i~~ili1,~*if'i'!l11,,"-9j~I~~~r'- , 1:1 :<,1 I',; ,--; I:" ;', ~ ::J ,,' ',I ;~-i >"""","""", - NICHOLE M. (CUTLIP) HALE, Plaintiff/Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2001-2502 - CIVIL TERM ROBERT L. CUTLIP, III, Defendant/Respondent IN CUSTODY PETITION TO MODIFY CUSTODY AND NOW comes the PlaintifflPetitioner, Nichole M. (Cutlip) Hale, by her attorneys, Irwin, McKnight and Hughes, and presents the following Petition to Modify Custody. L The Petitioner is Nichole M. (Cutlip) Hale, an adult individual residing at 57 Oliver Road, Enola, Cumberland County, Pennsylvania 17025. 2. The Respondent is Robert L. Cutlip, III, an adult individual residing at 1141 Longs Gap Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties are the natural parents of two (2) minor children, namely Madison M. Cutlip and Mikenna M. Cutlip, both born on March 7, 2000. 4. The parties are currently governed by a custody Order of Court dated August 2, 200 I, a copy of which is attached hereto and marked as Exhibit "A". 5. In June, the Respondent permitted his girlfriend, Lisa Robinson, to move in with him. Ms. Robinson has physically disciplined the minor children who do not like her. She also has been openly hostile to the Petitioner in front the minor children. "-",, '''''~' "-..,,>, ,- "";-~"~I""I_,y_,,,,,,,,___",,_,,,,""~,"n" _,,,, ~I,'_ o"'~-".t-~"" "_~~ ,._.._,,_,_., "~_"...,.,,,_,^,,',. __ -. __~, ,~"_~,_~ ^_~ , _~, .,'~_'U.c -- H " "I 1'1 ::: I,i "'I !;:I ';I ~ :: i :-1 -,t ',' ij~ '. i~i f:" :,:, .',:: 1"1 :":i !';I: [.'''''''''' ~ . 6. The Petitioner requests that the parties be directed to return the children to George Anderson for an evaluation. 7. The Petitioner desires that primary physical custody of said children remain with Petitioner, and periods of temporary custody to Respondent be limited to time when Lisa Robinson is not in the residence of the Respondent. 8. The best interests and permanent welfare of the minor children requires that the Court grant the Petitioner's request as set forth above. WHEREFORE, Petitioner, Nichole M. (Cutlip) Hale, respectfully requests that she retain primary physical custody and shared legal custody of Madison M. Cutlip and Mikenna M. Cutlip, as provided herein, with periods of temporary custody to Respondent as set forth above. Respectfully submitted, GHT & HUGHES By: ht, III, Esquire Atto ey for P tiff 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Supreme Court L D. No. 25476 Date: July 24, 2003 ""'-;-~---"~""" '" ,,-,., ,,~~,' '""", . ,,:,-~I_, 0 ..'~" ,Y-<'",'-~ ,_,..,,',' r,~,x--,' _"" "0, _ ~~_,,'~v"_l ,.~_ !_ ,_'~'__n_..,.,,".~ .y,. ~." ".%~___""__". __~__ --" ~-,'~ ,,,,"'" ~, VERIFICA nON The foregoing Petition to Modify Custody is based upon information which has been gathered by counsel and myself in the preparation of this action. I have head the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. ~hfo~ NICHO EM. HALE Date: July 24, 2003 ::i' 'c'_I" . ,"",0 ,< '"'V ~"'_~-""".__W-:o'lo,,'_-" -.,." ,_"_,~",, ~," ~..~",__" '~_'~', ~,_, ".,,-,..,<, C" _" ~. ~_^ ' > , ,-" ,,~, ". , '" '0z~ 1.- ' .-~'r_ , "".-. - .-c,.-c, ,.-..>,,-;-,,-,-. ~ ~ ~ ~ (\ ~ \) CJ\ '~-'" ,'-'''''-':'"-''',- -" '~-, - .,f:- a ~ ~ u )-' J J , fi';";!!I'Wl"~@Mi{"~l:'1'._ -1'~_ "'~ -.,;y:,; -'"'' ,"'-", "-~,*,,,,,,,,-,.I"-~:.' "i':~~';;p:-., l'l'rt:-t:!1i-;rnJlr ~ ~,-, o c: ~;, "'~_ .,1- CJ ,'",,) o -ri ::~ .",~. c:: (..... ~,,) -,,) .,.J <----..",-_:,1 , "."" ,"'O';~~ '!- -- .- N1CHOLE M. CUTLIP, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. ClVIL ACTION - LAW 2001-2502 ClVIL TERM ROBERT L. CUTLIP, ill, Defendant IN DIVORCE PRAECIPE TO 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 330 1 (c) of the Divorce Code. 2. Date and manner of service of complaint: A certified copy of the Complaint in Divorce was served upon the defendant, Robert L. Cutlip, III, on May 16, 2001, by certified, restricted delivery mail, addressed to him at 1141 Longs Gap Road, Carlisle, Peunsylvania 17013, with Return Receipt Number 70993400001849971803. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by Section 330l(c) of the Divorce Code: by plaintiff: July 27, 2001; by defendant: July 31, 2001. (b)(1) Date of execution of the affidavit required by Section 330l(d) of the Divorce Code: (b)(2) Date of filing and service of the plaintiffs affidavit upon the defendant: 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: (b) Date plaintiffs Waiver of Notice in Section 330l(c) Divorce was filed with the Prothonotary: August 2, 2001. Date defendant's Waiver of Notice Prothonotary: August 2, 2001. CUS A. Mc Attorney for Plaintiff SQUIRE "'''-,(-^'--- "~'--:'-:<',7""'-'--"""~''''.'~"''''"'''''_'''_'~-I~,.",~.., '." ,~,--c--' '_"" ' <.- '_1_'_" ,,",' ,~., ".r ~, ..~ ,,_ _~.>"= ,,'~" .'" ^,.",.".",-, "',' ,"".'""..<' ~ (~':J . ~ ,"".. '"" ,I., - ,c., ."~'~".<'oF,~ '"",7",.'" '~"'_ . ' ". ~. . "'''~, ~ ,_. _".~.~ ,~~ , c, H - ,~_~i~~~~:~_,~,,_ .! 1111 I j., . "':'''''' '1" 0 C'.) C.) c:: ~- -r, ;;;: J:>o :t1Q) C- 1l1n"'i t.~ "-'I Z.:r) ',t~ :<:5;' I (r.j . 1'0 .'.~,~' ;:$? ~~6 Ci s:: ' " -_. -'" ~O -'-. ;;;?i-Y -r'.'J., :S8 <:.) .8fTJ <: -, =< ::,v ~...' 01 ::n -<: '"'-":""""~'"'''''''''''';~'''''''''- <".", "~",,,,! I;";."lilil - . . 01-J50~ MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT made this I~ y.JJ day of 4~ .2001, by and between NICHOLE M. CUTLIP, (hereinafter referred to as "WIFE") and ROBERT L. CUTLIP, III, (hereinafter referred to as "HUSBAND"). WITNESSETH: WHEREAS, HUSBAND and WIFE were lawfully married on June 26, 1999, in the Cumberland County, Pennsylvania and separated on April 7, 2001. WIFE filed a Complaint in Divorce in Cumberland County, Pennsylvania, docketed at 01-2502 Civil Term on April 27, 2001. The parties hereto agree and covenant as follows: 1. The parties intend to maintain separate and permanent domiciles and to live apart from each other. It is the intent and purpose of this Agreement to set forth the respective rights and duties ofthe parties while they continue to live apart from each other. 2. The parties have attempted to divide their matrimonial property in a manner which conforms to a just and right standard, with due regard to the rights of each party. It is the intent of the parties that such division shall be final and shall forever determine their respective rights. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets. ,:,>1 -'I ":-,^_.,- ., '_-C'''''C'':.''''"''I'!I!!k - _~,', ~~",,=--,_" ."" -.-' Tu .C __" ~_" .~', _,,~ ", __" .~ ~" ".,~~ "~, - ,;y:;..,''-'-'l:i' _I , . 3. Further, the parties agree to continue living separately and apart from the other at any place or places that he or she may select as they have heretofore been doing. Neither party shall molest, harass, annoy, injure, threaten or interfere with the other party in any matter whatsoever. Each party may carry on and engage in any employment, profession, business or other activity as he or she may deem advisable for his or her sole use and benefit. Neither party shall interfere with the uses, ownership, enjoyment or disposition of any property now owned and not specified herein or property hereafter acquired by the other. 4. The consideration for this contract and agreement is the mutual benefit to be obtained by both of the parties hereto and the covenants and agreements of each of the parties to the other. The adequacy of the consideration for all agreements herein contained is stipulated, confessed, and admitted by the parties, and the parties intend to be legally bound hereby. Each party to the Agreement acknowledges and declares that he or she, respectively: a. is represented by counsel of his or her own choosing; b. is fully and completely informed of the facts relating to the subject matter of this Agreement and of the rights and liabilities ofthe parties; c. enters into this Agreement voluntarily after receiving the advice of counsel; d. has given careful and mature thought to the making of this Agreement; e. has carefully read each provision of this Agreement; and f. fully and completely understands each provision of this Agreement, both as to the subject matter and legal effect. This Agreement shall become effective immediately as of the date of execution. 2 "'" , I - '_c_': ,-,?""~',,, ,,,'~~! '.'.~I,-~.., ,_'0','_." ,.,,'~- ^~_'., ~ -,',- '~',-~.'--' ,,~---- '"' '_'-"_'~.'_''','=',.~''~' _0 ,~ _< . - "~"';""i. '" .. . . 5. It is the purpose and intent of this Agreement to settle forever and completely the interest and obligations of the parties in all property that they own separately, and all property that would qualifY as marital property under the Pennsylvania Divorce Code, Title 23, Section 40l(e), and that is referred to in this Agreement as "Marital Property", as between themselves, their heirs and assigns. The parties have attempted to divide their Marital Property in a manner that conforms to a just and fair standard, with due regard to the rights of each Party. The division of existing Marital Property is not intended by the parties to constitute in any way a sale or exchange of assets, and the division is being effected without the introduction of outside funds or other property not constituting a part of the marital estate. It is the further purpose of this Agreement to settle forever and completely any obligation under the Pennsylvania Divorce Code relating to spousal support or alimony. 6. Each party represents and warrants that he or she has made a full and fair disclosure to the other of all of his or her property interests of any nature, including any mortgage, pledge, lien, charge, security interest, encumbrance, or restriction to which any property is subject. Each party further represents that he or she has made a full and fair disclosure of all debts and obligations of any nature for which he or she is currently liable or may become liable. Each further represents and warrants that he or she has not made any gifts or transfers for inadequate consideration of Marital Property without the prior consent of the other. Each Party acknowledges that, to the extent desired, he or she has had access to all joint and separate State and Federal Tax Returns filed by or on behalf of either or both Parties during marnage. 3 - '':' ""i"',".~-_~-"J,'- ,..0 ,.""",:~_.",~",,.,,~, .,_ .r._,""'" "'~"~ __" ," ,. " _'-' ,--,',,"."''> ""r-<,-- .. ." ,_ " ~ m . ~~. ~~_" 0'" _ ".. .. . . 7. REAL ESTATE: The parties do not own any real estate. 8. DEBTS: HUSBAND will be solely responsible for his own debts. WIFE will be solely responsible for her debts. HUSBAND agrees to assume all liability for the payment of the first mortgage and home equity loans until the real estate is sold. HUSBAND will indemnify and hold harmless WIFE from all obligation related to these loans. WIFE will be solely responsible for payment of the automobile loan until the real estate is sold. WIFE will indemnify and hold harmless HUSBAND from any claim made against him related to the automobile loan. HUSBAND agrees to pay off the loan at Waypoint Bank which has an approximate balance of Four Hundred Forty and no/I 00 ($440.00) Dollars. 9. SPOUSAL SUPPORT: It is the mutual desire of the parties that HUSBAND will not be required to pay support or alimony pendente lite to the WIFE for herself. WIFE will not provide any financial support or alimony pendente lite to the HUSBAND. The parties also waive any right they have to receive alimony payments from the other following the entry of the Divorce Decree in this matter. Any child support will be as ordered by the Cumberland County Office of Domestic Relations. 4 ';~,;",~,,,,",-p,,,,-"'-"I .:-. ~';."'_' "~_,*",,,,,,,,..,, ,'" _'-""',-;'(>'."~" '~" '''''''."?_ ,;'C '<0'. .I"L..".~., _'""~,,-n,,' """ .,~ ~"r,~, ,> <,,, ", I _ <. ~~ ~.r.,", " ~~,=~~,~. ~"_'" ~.." - . -, -,~, ' ,. ~ ...1 . . 10. PERSONAL PROPERTY: The parties agree that the personal property shall be divided as follows: HUSBAND shall receive the following items: . a. The personal property in his possession. b. His bank accounts; c. Any life insurance policy; d. His employee benefits; and e. His IRA. WIFE shall receive the following items: a. The personal property in her current possession., b. Her bank accounts; c. Any life insurance policy; and d. Her employee benefits. The WIFE hereby waives all right and title which she may have in any personal property of the HUSBAND. HUSBAND likewise waives any interest which he has in the personal property of the WIFE. Henceforth, each of the parties shall own, have and enjoy independently of any claim or right of the other party, all items of personal property of every kind, nature and description and wherever situated, which are then owned or held by or which may hereafter belong to the HUSBAND or WIFE with full power to the HUSBAND or the WIFE to dispose of same as fully and effectually, in all respects and for all purposes as if he or she were unmarried. 5 . """,'~"I "~'--?i'~'''''''~_'''_'~'''M_~"_""",,,-,,''___'''"'_.,,+,.I!'!liI...,,~_~,,~_ ,'~"_ ~_'_~~~""__"""'_"'_ ,.,~ ,. ~ "~.,.~.~ ,.~, ,. r.'" "". -, , . Each party agrees that neither, will incur obligations, liens or liabilities on account of the other and that from the date of this Agreement, neither party shall contract or incur obligations, liens or any liability whatsoever on account of the other. 11. AUTOMOBILES: a. HUSBAND agrees to waive any and all interest which he may have in the automobiles in possession of the WIFE. b. WIFE agrees to waive any and all interest which she may have in the automobiles in possession of the HUSBAND. They each waive any claim which they have in any automobile owned by the other party. 12. INSURANCE AND EMPLOYEE BENEFITS: The parties agree that any life insurance policies on the life of HUSBAND or WIFE or any other employee benefits, including but not limited to retirement, profit sharing or medical benefits of either party, shall be their own. WIFE waives all right, title and claim to HUSBAND'S employee benefits, and HUSBAND waives all right, title, and claim to any of WIFE'S employee benefits. 13. BENEFITS AND BANK ACCOUNTS: WIFE agrees to waive all right, title and interest which she may have in the savings or checking or any other bank accounts of the HUSBAND. The HUSBAND agrees to waive all interest which he has in the bank accounts of the WIFE. 6 """:,"'-'"--;1- "'~,-'!~".Y~,~ ."".'_','H."~,.g___"~",_~~~~~,'''~,<I!!!'1I,,,~,_.,,.,_~~<.,,,,~._" ';-._' _. ".'~ ",'_ ,~".." '--=--' ~"--''-.~ <~. .~, ,~ .-- .~ , -~~ = " ..> . . 14. DIVORCE: The parties both agree to cooperate with each other in obtaining a final divorce of the marriage. It is agreed that the parties will execute and file the consents necessary to obtain the divorce. Any party who fails to cooperate with obtaining the Divorce shall pay all the costs and legal fees of the party who is seeking the divorce. 15. BREACH: If either party breaches any provisions of this Agreement, the other party should have the right, at his or her election, to sue for damages for such breach or seek such other remedies or relief as may be available to him or her, and the party breaching this contract will be responsible for payment of legal fees and costs incurred by the other in enforcing their rights under this Agreement. 16. ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. 17. VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel, and each party acknowledges that the Agreement is fair and equitable, and that it is being entered into voluntarily, and that it is not the result of any duress or undue influence. The provisions of this Agreement are fully understood by both parties and each party acknowledges that the Agreement is fair and equitable, that it is being entered into voluntarily, and that it is not the result of any duress or undue influence. 7 :",.-;'"'"-1" :--f""'''''=<','''''::r'T~'''J'''''.'~."".''<-"'~"'''''_~~'''''~'''1l"'1'__'_.____'_., .=- '~"~',,' _"__~' ~> __"r,l'" "... ~~"'_ _. .~ ,-- "_M ~ <. _~ ',',".,_ _ .. , , 18. ENTIRE AGREEMENT: This Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. 19. APPLICABLE LAW: This Agreement shall be construed under the Laws of the Commonwealth of Pennsylvania. 20. PRIOR AGREEMENTS: It is understood and agreed that any and all property settlement agreements which mayor have been executed prior to the date and time of this Agreement are null and void and of no effect. 21. PAYMENT OF COSTS AND LEGAL FEES: The parties agree to pay for their own costs and legal fees required to obtain and complete the divorce. 22. WAIVER OF CLAIMS AGAINST ESTATES: Except as herein otherwise provided, ii each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire, under the present or future laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including without limitation, dower, courtesy, statutory allowance, widow's allowance, right to take in intestacy, right to take against the Will of the other, and right to act as administrator or executor of the other's estate, and each will, at the request of the other, execute, acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims. 8 ,<~ ,- , . IN WITNESS WHEREOF, the parties hereunto have set their hands and seals the day and year first above written. I ~ 9 C'-,-, "'" '1~ .,~\-- ~~, - ,- __'~ ,'- > ;-, '_'~~c":,\'1' "1~k-:~T'\',~".0 c--',,,.__..~,__~__"'__~'.':"':-__c_ "'~'" ___.,~. " 1'-.' ~'~_-~I<' _ ,~, ".'_' ~ " ~"'" 'n ",,,,,~__,, ",'_ __',c" i.. (SEAL) -- ,.'t. -~ ., -., ..,." ".~', ~'''''__ .~, - .~'.~ '. COMMONWEALTH OF PENNSYLVANU SS: COUNTY OF CUMBERLAND PERSONALLY APPEARED BEFORE ME, this (fp """ day of -tu..t~ a Notary Public, in and for the Commonwealth of Pennsylvania and~ County of 2001, Cumberland, NICHOLE M. CUTLIP, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Marriage Settlement Agreement, and acknowledges that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. No rial Seal Martha L. Noe , Notary Public Carlisle Boro, Cumbenand County My Commission Expires Sept. 18, 2003 Member, Pennsylvania AssocIation 01 Notanes COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF CUMBERLAND PERSONALLY APPEARED BEFORE ME, this ? Q D day of fl ~ 2001, a Notary Public, in and for the Commonwealth of Pennsylvania and County of Cumberland, ROBERT L. CUTLIP, III, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Mamage Settlement Agreement, and acknowledges that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand . al seal. NOTARIAL SEAL Michelle L Salienberger, Notary Public Fayetteville, Franidin County 10 My Commission Expires Oct 5, 2002 1 '-',.,.",.." .'" .. ." " " ,^".~', . I..~h~,..-, "'" ,'""~-"",, .l'. 'I' ~' ." , o. "' . .. 0._ ~<_~, . '_ "',<, - il!II >,. ~<; Kp " ~","-""".,.,<,-/.,,,,.. , ,,<' .'" -, - ~'-'" ",~ ~ . ~,. .,--- ,,".-' - - ~"-"'ITJ lfiiilll1Jilm n 'iT" TI'T"1!1iI1' . . 0 (::--, 0 c: -n s: "'" -""I \')('.0 '- "r..-.-,. rlln-; G") h-,;2- 2:-:0 I .'::zR ZS:~ ~~:?,o I'J ., I '---";,..} [;:: C ..'0 ' " __L..--;"', j> \, , _.\... ~S~~ Z 0 5> 00 c: .'-'1 L t....., "1:<- ::{ CD 1.0 -< ; j~ ."' ~ ,.! '- r""",:~~l'~<~~'\\~~~Il",." ___~~r.llnlll~",."..":'1 ''''''_'. ""'~ - ~" . ,- SOCIAL SECURITY INFORMATION SHEET PURSUANT TO 23 Pa.C.S.A. SECTION 4304.1 (a) (3) ALL DIVORCES MUST INCLUDE THE PARTIES SOCIAL SECURITY NUMBER PLEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN TO THE PROTHONOTARY'S OFFICE DATE: Au~ust 2, 2001 DOCKET NUMBER: 2001-2502 CIVIL TERM PLAINTIFF~ SS# 175-60-0561 NAME: NICHOLE M. CUTLIP DEFENDANT~ SS # 172-66-4938 NAlJE: ROBERT L. CUTLIP, III ~" , I I~ ;~ T- " , .,....,..,' NICHOLE M. (CUTLIP) HALE, Plaintiff/Petitioner ~) JUt. ,2003 : IN THE COURT OF COMMON PLEAS 0 ' , : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2001-2502 - CIVIL TERM ROBERT L. CUTLIP, III, Defendant/Respondent IN CUSTODY ORDER OF COURT AND NOW, this day of , 2003, upon consideration of the attached Petition, it is hereby directed that the parties and their respective counsel appear before Esquire, the conciliator, at , on the _ day of , 2003 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 carmot be accomplished, to defme 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 this conference may provide grounds for entry of a temporary or permanent order. By the Court, By: Dawn Sunday, 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 OmCE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 1-800-990-9108 2:,""",,"""'1 -.".',,--. "--~" '^"_',.,"i)'~P.lfflk..','~_"_",!_,.,"",_"_<~~_",,_,"_,,,.,..,""_ "" _.~_ .', ~ "~"^__,'_..~~'~..."_ ,__~ "'^ .. 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 scheduling conference or hearing. ~ ~ ," ^' --. C";-'-"'+_'~''''''_''_ '__.' .,~ - -p'.' "" ,'" -~"'_o'I'!;'iI~;' -'. ,_,-- ~"', <'_""'-~ <__"'" ~o__. __ , '..'1 ,'.- .... .~'. ~,~. NICOLE M. CUTLIP Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2001-2502 Civil Term ROBERT 1. CUTLIP, III Defendant CIVIL ACTION - Custody ORDER OF COURT AND NOW, upon consideration ofthe attached Complaint, it is hereby directed that the parties and their respective counsel appear before Esquire, the Conciliator, on the _ day of , 2002, at .m., in the Attorney's Conference Room, 4th Floor, Cumberland County Courthouse, Square, Carlisle, Pennsylvania, 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 a~e five and older shall also be present at the Conference. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent Order. FOR THE COURT, Date of Order: 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, PAl 70 13 Telephone: (717) 249-3166 ':-", , '""1 T~. ' ^, ~. . "., ' ",_ ,.._,. '1r:.I''''''~~", ,," !Cc- ,. ~ "'"'"" _," "_,W, , _ ~ ,R .,~_