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Home My WebLink About01-03534 Plaintiff JUN 11 Z001 f/J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ROSA M. KING, vs. NUMBER: 01 - 2.531 G0~L~~ CHRISTOPHER V. KING, Defendant CUSTODY ORDER AND NOW, this /3- day of "/"....... , 2001, upon consideration of the within Motion, Stipulation, and Complaint, it is hereby Ordered as follows: 1. It is the intention of the parties and the parties agree that they will share joint legal custody of their minor child, QUIN MARIE KING, born June 13, 1998. The parties agree that major decisions concerning the child, including, necessarily limited to, the child's health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in the child's best interests. Each party agrees not to impair the other party's right to shared legal custody of the child. Each party agrees not to attempt to alienate the affections of the child from the other party nor to permit any third person to attempt to so alienate the affections of the child from the other party. Each party shall notify the other of any activity or circumstance concerning the child that could reasonably be expected to be of concern to the other. Day-to-day decisions shall be the responsibility of the '1\~, ^ \,,- ,'""",,,''''.~,,^.," '"," , '.-'~' t' ~ .1'.~I!!I'I7"',.,o_~ ~"~,, ' . '1 ' . ,.--.~ ""'~--",--,..",.,;,i;" """joill~~r"'" ',".~'-- ;;;.... ".. ;"~;ji:i:! ,,",,,,,,J,~~,, ,;"JIlJ!QDL"",~~,~U'UJJ;!lL;:J!U~,~ ,. ,< -c~ "":,"",)J,,, ,J,,,,_",..,,,,,""",," ~ c' 'R"", """, '"" ' ,'<' _H '" ',", ~.,_ O~ :'; " 01 JU\! \ 3 --\C~: ~":.: .:(~\:(JTA.8Y "", ",. :0: I, n 1"'\ l... ........ CUi'f1SE,CIL,;'I:J COUNTY PENNSYLVi\NIA ."",,",. _,' -''"i II ~!I ~~ 111. 1 iil , " '~ ".~~ party then having physical custody. With regard to any emergency decisions which must be made, the party having physical custody of the child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that party shall inform the other of the emergency and consult with him or her as soon as possible. Each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports given to either party . 2. Mother, ROSA M. KING, shall have primary physical custody of the subject minor child. 3. Father, CHRISTOPHER V. KING, shall have liberal rights of temporary physical custody of the minor child as the parties shall from time to time agree. BY THE COURT: J. .~ -~~*- ~~ 0' \/\.9\')' I~ , ?""~","'~"'-''' "":\"'~,.,""""v,.,.r'...,1 '~'..." ~,',I~I", ""~__'" ,.,.-- ~. 1 .- ',' Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NUMBER: 01- 35.3 'f ~ -r .u- ROSA M. KING, vs. CHRISTOPHER V. KING, Defendant CUSTODY MOTION NOW COMES the Plaintiff, ROSA M. KING, by and through her attorney, Charles E. Petrie, and respectfully represents as follows: 1. That Plaintiff is ROSA M. KING, an adult individual currently residing at 1710 Market Street, Apartment 16, Camp Hill, County of Cumberland, Pennsylvania. 2. That Defendant is CHRISTOPHER V. KING, an adult individual currently residing at 526 Penn Avenue, Basement, Sinking Springs, County of Berks, Pennsylvania. 3. That Plaintiff and Defendant are the natural parents of a minor child, QUIN MARIE KING, born June 13, 1998. 4. That the parties have entered into a Stipulation concerning the matters of custody and visitation with respect to the minor child, and the said Stipulation is attached hereto. '"1). , ,-" ',.., ,__,,"'- ".~,~".,'f<','~' ,,,..",,,,- ,'I" '.'>l '~~'~I"'I "_~""'.'~.". .~".,"",," .. 5. That the parties desire that said Stipulation be entered as an Order of Court. WHEREFORE, Plaintiff respectfully requests that Your Honorable Court enter an Order pursuant to the attached Stipulation. Respectfully submitted "1,/ U A c.~c ~ CHARLES E. PETRIE 3528 Brisban Street Harrisburg, PA 17111 (717) 561-1939 Attorney for Plaintiff ;,,--,",.,~., 1'-' '-""~''''~:;~'_~c;::'''r.'c~.._ ",,,,--_,,,,,,,,~ 1,,1, ,_,0,,0. "~''''','''<;-.'~':7,'. ,_~.,' ' '1-' "~ ",' . ,',' ~ r - - .'."- ,- Plain tiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NUMBER: 01- 36 3'1 ~ T-UA- ROSA M. KING, vs. CHRISTOPHER V. KING, Defendant CUSTODY COMPLAINT FOR CUSTODY NOW COMES the Plaintiff, ROSA M. KING, by her attorney, Charles E. Petrie, and respectfully represents as follows: 1. Plaintiff is ROSA M. KING, who currently resides at 1710 Market Street, Apartment 16, Camp Hill, County of Cumberland, Pennsylvania. 2. Defendant is CHRISTOPHER V. KING, who currently resides at 526 Penn Avenue, Basement, Sinking Spring, County of Berks, Pennsylvania. 3. Plaintiff seeks to have rights of primary physical and shared legal custody with respect to QUIN MARIE KING, born June 13, 1998. The child was not born out of wedlock. The child is presently in the custody of Plaintiff, ROSA M. KING. Since birth the child has resided with the following persons and at the following addresses: From birth until October, 2000, with both parents in Pennsylvania; from October, 2000, until the present, with Plaintiff at 1710 Market Street, Apartment 16, Camp Hill, Pennsylvania. The mother of the child is ROSA M. KING, who currently resides at 1710 Market Street, Apartment 16, Camp Hill, Pennsylvania. She is not married. ~~ - '~I c'" ,.' "~".""'",I'''''' ~,"'~ ,. -I""'''' "",.1"".1. ~, -,'~ ~:,. ,'~ ".",.., " The father of the child is CHRISTOPHER V. KING, who currently resides at 526 Penn Avenue, Basement, Sinking Springs, Pennsylvania. He is not married. 4. The relationship of the Plaintiff to the child is that of mother. The Plaintiff currently resides with the child. 5. The relationship of the Defendant to the child is that of father. He currently resides alone. 6. The Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or in another court. The Plaintiff has no information of a custody proceeding concerning the custody of the child in this or in another court. Plaintiff does not know of a person not a party to these proceedings who has physical custody of the child or who claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by confirming rights of primary physical and shared legal custody in Plaintiff. 8. Each parent whose parental rights to the child have not been terminated and the persons who have physical custody of the child have been named as parties to this action. "I '<:"':~'''''''!~: !""'"..,, '::'----~,.j - ?"X'''<'r''ll,.' ,.', ~,_, "',~""''''''' "1 , .~.~," , ., 9. The parties have entered into a Stipulation, attached hereto, setting forth their agreement concerning custody of the minor child. WHEREFORE, Plaintiff requests the Court enter an Order confirming rights of primary physical and shared legal custody in Plaintiff. Respectfully submitted, C4-..-L f"A4 CHARLES E. PETRIE 3528 Brisban Street Harrisburg, PA 17111 (717) 561-1939 Attorney for Plaintiff j? ,~. '"I , ",,".,..,)t",f?"~I'"""""/,~ ',,--".', '1""'1 "','" , "I,....> .~,~" - '0, ,., :"",~.""""'.~~"'."'" ,'~ " ~ ., COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN I verify that the statements in the foregoing Complaint 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. 5/ J,. ') 10 I DATE .., ,:." I i~~ v ROSA M. KING W\ )~/7 u .,~ ":""1 ,. "'C.''', ' v. .", ,. . ,.,,"~dfl!ll ," ,_,', ~c~, .' '." '~: ,~ " . - ~ . , , Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ROSA M. KING, vs. NUMBER: CHRISTOPHER V. KING, Defendant CUSTODY STIPULATION AGREEMENT, made this 25th day of May, 2001, by and between CHRISTOPHER V. KING, hereinafter referred to as "Father," and ROSA M. KING, hereinafter referred to as "Mother." WITNESSETH: WHEREAS, the parties hereto are the natural parents of a minor child, QDIN MARIE KING, born June 13, 1998; and WHEREAS, the parties have reached an agreement concerning the issues of custody and partial custody; and WHEREAS, the parties desire that this Stipulation be entered as an Order by the Court of Common Pleas of Cumberland County, Pennsylvania; NOW THEREFORE, intending to be legally bound, it is hereby agreed as follows: 1. It is the intention of the parties and the parties agree that they will share joint legal custody of their minor child. The parties agree that major decisions concerning the child, including, but not necessarily limited to, the '!<'r", ~ >""".'"~o"".'Wi:"'.-',,lff-f'" ',.',7".", ~. ."I"!!'I ,~,"__,' " , ~,.~ child's health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in the child's best interests. Each party agrees not to impair the other party's right to shared legal custody of the child. Each party agrees not to attempt to alienate the affections of the child from the other party nor to permit any third person to attempt to so alienate the affections of the child from the other party. Each party shall notifY the other of any activity or circumstance concerning the child that could reasonably be expected to be of concern to the other. Day-to-day decisions shall be the responsibility of the party then having physical custody. With regard to any emergency decisions which must be made, the party having physical custody of the child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that party shall inform the other of the emergency and consult with him or her as soon as possible. Each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports given to either party. 2. Mother, ROSA M. KING, shall have primary physical custody of the subject minor child. R,..'S , ~, '0\".~J'['''''-''''"~,~,,~,~,~, ",-"',_ .'.l~"" ,>'7"1~1 ".' . ..-a. ,.,~, ~., ,.., .., 3. Father, CHRISTOPHER V. KING, shall have liberal rights of temporary physical custody of the minor child as the parties shall from time to time agree. IN WITNESS WHEREOF, the parties have hereunto set their hands and official seals. ~~A~ WITNESS "~"1 i~ ~ 16- ck-< /.A'?-9 WITNESS r--" ~./ U?L.., CHRISTOPHER V. KING / ~'","". ~ - ~. ff";. y~,,<; ;t~"~,, ~ ""~" '},';' ,'~~ ,'~'I~'l.,"'.~ ,'",; ","".''''" . ",,"'." ,<, ~ "' ".,-, , "~ "" "' ~, (:s to I I. , 'I II ,,, ~i ~i, o. ~ ~ > ,,~. ,,,' .~-' " =' ~~,,". -~ ,r.. ~', ' - .,. ~,." ~''',-",.., ~...' "~Y">'''"'-''''.>,' > ~ ,,~., " ,",'_. .~.. , .... "'"""-," ..... .."'.~..*""=","',, H ";""m~: ?V & ~ l:l ~ B "- 1...; VI ..... 8" 0 10 r- -vl ~ F ~ ~ ""T~_" ,. ~, "'~lrj.:)\~~.",.~, , o r- --,:,::;;- ---0f;-~' SIC", .:;......J' :-7r (.f) .r.-' ?;~~ <'""'---' :i;;c ~.~C) ;>o-C z ::<! .J,.nllflfl{! , C) ,~ -.- -'~;<" ~- _! -0 ':};: ~ N \0 ,-' -"'E~ ,--','; -~l ,-,.:-r, ::J1(;::i Sj!~} i3i:~ .., ;);'- ~ '" 9 . ~," ~