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HomeMy WebLinkAbout01-03970SARAH E. BARONE 1N THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. LORENZO E. ARCHER, JR. • 01-3970 CIVIL ACTION LAW DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, July 05, 2001 , upon considerafion of the attached Complaint, it is hereby duected that parties and their respective counsel appear before Jacqueline M. Verney, Esq. ,the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, July 25, 2001 at 8:30 AM for aPre-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 nanow 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 hearing. FOR THE COURT, By: /s/ ac ueline M. Verne Es . 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 Cu~lisle, Pennsylvania 17013 Telephone (717)249-3166 r '.. ,: ~ ~C~'d4':il ~ ~.::, ,' db'1 7-(~ D/ ~ ~ ~ ~! ~~ ~ l~ G/ ;o T SARAH E. BARONE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. No. OI_ 3q~o Gwl . CIVIL LORENZO E. ARCHER, JR., Defendant ORDER OF COURT be placed in Sarah E. Barone, natural mother. The Plaintiff is permitted to take the child out of the country for a family vacation she has enjoyed for years. AND NOW, upon consideration of the attached Petition, it is hereby directed that the parties and their respective counsel appear before , the conciliator, at 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. All children age five or older shall also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. Pending the above hearing, custody of the said child shall FOR THE COURT, BY: SAIDIS SHUFF, FLOWER & LINDSAY ATTORNEYS•AT•LAW 26 W. High Street Carlisle, PA Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 SARAH E. BARONE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. CIVIL LORENZO E. ARCHER, JR., Defendant ORDER OF COURT You, Lorenzo E. Archer, Jr., Defendant, have been sued in court to obtain custody, of the child: Jenna N. Archer-Barone. You are ordered to appear in person at Court Room No. of the Cumberland County Courthouse, Carlisle, Pennsylvania on 2001 at m., for a hearing. If you fail to appear as provided by this order, an order for custody, partial custody or visitation may be entered against you or the court may issue a warrant for your arrest. 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. Office of the Court Administrator One Courthouse Square, 4th Floor Carlisle, Pennsylvania 17013 (717) 240-6200 SAIDIS SHUF$ FLOWER & LINDSAY 26 W. Nigh Street Carlisle, PA BY THE COURT: J. A SARAH E. BARONE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. o i- 39 no Cu;~.l I,c,,- CIVIL LORENZO E. ARCHER, JR., Defendant . SAIDIS SHUFF, FLOWER & LINDSAY ATTOItNCYS•AT•LAW 26 W. High Street Carlisle, PA PETITION FOR CUSTODY AND NOW comes the Plaintiff, Sarah E. Barone, by and through her attorneys, Saidis, Shuff, Flower & Lindsay and respectfully avers the following: 1. The Plaintiff is Sarah E. Barone, residing at 102 Lincoln Street, Apt. B., Carlisle, Cumberland County, Pennsylvania. 2. The Defendant is Lorenzo E. Archer, Jr., residing at 1629 Derry Street, Harrisburg, Dauphin County, Pennsylvania. 3. Plaintiff seeks custody of the following child: Jenna N. Archer-Barone, date of birth 11/10/98. The child's residence is 102 Lincoln Street, Apt. B., Carlisle, Cumberland County, Pennsylvania. 4. The child was born out of wedlock. 5. The child is presently in the custody of mother, who resides at 102 Lincoln Street, Apt. B, Carlisle, Cumberland County, Pennsylvania. 6. During the past five years, the child has resided with the following persons and at the following addresses: Persons Sarah E. Barone Addresses 102 Lincoln Street Apt. B, Carlisle, PA Dates birth - present „~ r 7. The mother of the child is the Plaintiff, Sarah E. Barone, residing at 102 Lincoln Street, Apt. B, Carlisle, Pennsylvania. 8. She is not married. 9. The father of the child is Lorenzo E. Archer, Jr., residing at 1629 Derry Street, Harrisburg, Pennsylvania. 10. He is not married. 11. The relationship of Plaintiff to the child is that of mother. The Plaintiff currently resides with the following persons: Name Relationship Jenna N. Archer-Barone daughter 12. The relationship of Defendant to the child is that of SAIDIS ? SNUFF, FLOWER & LINDSAY '~ Arroiuvevs•Aruw ~y 26 W. High Street Carlisle, PA father. The Defendant currently resides with the following persons: Nam- Relationship Dawn Archer and her four children Sister and nieces and nephew 13. Plaintiff has not participated as a party or witness, or in another capacity, on other litigation concerning the custody of the child in this or another court. The court, term and number, and its relationship to this action is: Not applicable. 14. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. The court, term and number, and its relationship to this action is: Not applicable. 15. 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. The name and address of such person is: Not applicable. 16. The best interest and permanent welfare of the child will be served by granting the relief requested because the child has lived with Plaintiff all of her natural life and does not know the Defendant as a father, other than after her birth, and has expressed no interest in having any contact with his child. Further, the Plaintiff wishes to travel out of the country and needs to have supporting documents showing that she has primary physical custody of this child. WHEREFORE, Plaintiff requests the court to grant Plaintiff custody of the child. Respectfully submitted, SAIDIS SHUFF, FLOWER & LINDSAY ATTORNeYS•AT•LAW 26 W. High Street Carlisle, PA Dated: ~P- 2 _Tj 1 SAIDIS, SHUFF, FLOWER & LINDSAY Johnn~/ff. KoaSecky,/~squire Attorney I. # 53147 26 West High Street Carlisle, PA 17013 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. DATED : ~ ~ f O' ' rah Barone CERTIFICAT SERVICE On this ~ day of ~~ ~~ Q 20~, I, hereby certify that I served a rue and correct copy of the foregoing Petition for Custody upon all parties of record via United States Mail, postage prepaid, addressed as follows: Lorenzo E. Archer, Jr. 1629 Derry Street Harrisburg, PA 17101 SAIDIS, CHUFF, FLOWER & LINDSAY ;y,, _ ~~ ~~ r O n ~- ~'=~ ; r_ r >~, v~_' _` .~ cr. '~~ C.J1 --a :~'r' -~ ;7 rn SARAH E. BARONE, Plaintiff v. LORENZO E. ARCHER, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-3970 CIVIL ORDER OF COURT AND NOW this ~ day of July, 2001, upon ', SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Stree[ Carlisle, PA consideration of the within Petition, Petitioner, Sarah E, Barone, is permitted to take her child, Jenna N. Archer- Barone, born on November 10, 1998, out of the United States and into Canada for a family vacation and from Canada into the United States. Sarah E. Barone shall appear at a custody conciliation scheduled for July 25, 2001, at 8:30 a.m. at Cumberland County Courthouse or at such other time as may be syet by the-~Conci-l-i-a~~tor.rTl~t c,c~l~~.}~5{~z~~ re~w~ l~P~~~or~c.3~ to ~G V11~1G~ ~1 ZtCS Ta l`e a.9 l's\ l5'IL S~! ~ ~~-.. t~~ V2GLtt~'. BY THE COURT: ., r -- -- , i` ° ,, . _. i_ .. .r +_ SARAH E. BARONE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. N0. 01-3970 CIVIL LORENZO E. ARCHER, JR., Defendant PETITION FOR EMERGENCY RELIEF AND NOW comes the Plaintiff, Sarah E. Barone, by and through her counsel, Saidis, Shuff, Flower & Lindsay and petitions this Honorable Court as follows: 1. The Petitioner is Sarah E. Barone, residing at 102 Lincoln Street, Apt. B, Carlisle, Pennsylvania. 2. The Defendant is Lorenzo E. Archer, Jr., residing at 1629 Derry Street, Harrisburg, Dauphin County, Pennsylvania. 3. The parties are the parents of a child, Jenna N. Archer-Barone, born November 10, 1998 4. Respondent has not seen the child since January, 1999, except on one occasion when the child was 6 weeks old. 5. Petitioner filed a Petition for Custody on June 26, SAIDIS SHUFF, FLOWER & LINDSAY ATTORI~YS•AT•LAW 26 W. High Street Carlisle, PA 2001. A copy of the Petitioner is attached hereto as Exhibit oAu 6. Annually, Petitioner and her family travel for a family vacation to Canada. Petitioner intends to leave on that family vacation with the child on July 7, 2001. The border authorities advise that the child may not re-enter the country without documentation from a Court indicating that she has custody of the child or a letter from the child's father indicating that he has no objection that she travel with the child. 7. Upon information and belief, Petitioner will not be able to obtain any cooperation from the Respondent and seeks a Court Order to permit her to take her family vacation. 8. Although a conciliation Order has not yet been entered, the undersigned believes that the conciliation is scheduled for July 25, 2001, at 8:30 a.m. with Conciliator Jacqueline Verney. Petitioner can attend the conciliation and requests the entry of an Order in the form attached. WHEREFORE, Petitioner prays this Honorable Court for an Order permitting her to take this child into Canada and return her to the United States for a family vacation. Respectfully submitted, SAIDIS SHUFF, FLOWER & LINDSAY ATI'ORNEYS•AT•LAW 26 W. High Street Carlisle, PA Dated: / & LINDSAY Carol J. i y, Esqui, Attorne I.D. # 44693 26 West igh Street Carlisle, PA 17013 Attorney for Petitioner SARAH E. BARONE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. No. a1~34 70 CIVIL LORENZO E. ARCHER, JR., Defendant ORDER OF COURT AND NOW, upon consideration of the attached Petition, it is hereby directed that the parties and their respective counsel appear before , the conciliator, at 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. All children age five or older shall also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. Pending the above hearing, custody of the said child shall be placed in Sarah E. Barone, natural mother. The Plaintiff is permitted to take the child out of the country for a family vacation she has enjoyed for years. FOR THE COURT, BY• Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or SAIDIS hearing. SHUF$ FLOWER & LINDSAY y0U SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO ^errou+ets•nruw 26 W. High Street NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE Carlisle, PA 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 SARAH E. BARONE, Plaintiff v. LORENZO E. ARCHER, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ORDER OF COURT You, Lorenzo E. Archer, Jr., Defendant, have been sued in court to obtain custody, of the child: Jenna N. Archer-Barone. You are ordered to appear in person at Court Room No. of the Cumberland County Courthouse, Carlisle, Pennsylvania on 2001 at .m., for a hearing. If you fail to appear as provided by this order, an order for custody, partial custody or visitation may be entered against you or the court may issue a warrant for your arrest. 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. Office of the Court Administrator One Courthouse Square, 4th Floor Carlisle, Pennsylvania 17013 (717) 240-6200 SAIDIS SH[IFF, FLOWER & LINDSAY BY THE COURT: J. 26 W. Aigh Street Carlisle, PA SARAH E. BARONE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. CIVIL LORENZO E. ARCHER, JR., Defendant PETITION FOR CUSTODY cam. ==' T c. -_~ AND NOW comes the Plaintiff, Sarah E. Barone ~Iay ar~d _' OJ?.. ~~ _ through her attorneys, Saidis, Shuff, Flower & Lir~~~y ~~d -~' respectfully avers the following: y'~} ~ _ ~~ G ~r -G CT1 -G 1. The Plaintiff is Sarah E. Barone, residing at 102 Lincoln Street, Apt. B., Carlisle, Cumberland County, Pennsylvania. 2. The Defendant is Lorenzo E. Archer, Jr., residing at 1629 Derry Street, Harrisburg, Dauphin County, Pennsylvania. 3. Plaintiff seeks custody of the following child: Jenna N. Archer-Barone, date of birth 11/10/98. The child's residence is 102 Lincoln Street, Apt. B., Carlisle, Cumberland County, Pennsylvania. 4. The child was born out of wedlock. 5. The child is presently in the custody of mother, who SAIDIS SHUF$ FLOWER & LINDSAY ~!r .. =.: ~TrORH8V3•ATHAW 26 W. High Street Carlisle, PA resides at 102 Lincoln Street, Apt. B, Carlisle, Cumberland County, Pennsylvania. 6. During the past five years, the child has resided with the following persons and at the following addresses: Persons Addresses Dates Sarah E. Barone 102 Lincoln Street birth - present Apt. B, Carlisle, PA ;Ta 7. The mother of the child is the Plaintiff, Sarah E. Barone, residing at 102 Lincoln Street, Apt. B, Carlisle, Pennsylvania. 8. She is not married. 9. The father of the child is Lorenzo E. Archer, Jr., residing at 1629 Derry Street, Harrisburg, Pennsylvania. 10. He is not married. 11. The relationship of Plaintiff to the child is that of mother. The Plaintiff currently resides with the following persons: Name Relationship Jenna N. Archer-Barone daughter 12. The relationship of Defendant to the child is that of SAIDIS SHUF$ FLOWER & LIlVDSAY - ~~'~Troxr~Arxaw ze w. eisn street Carlisle, PA father. The Defendant currently resides with the following persons: Name Relationship Dawn Archer and her four children Sister and nieces and nephew 13. Plaintiff has not participated as a party or witness, or in another capacity, on other litigation concerning the custody of the child in this or another court. The court, term and number, and its relationship to this action is: Not applicable. 14. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. .; The court, term and number, and its relationship to this action is: Not applicable. I 15. 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. The name and address of such person is: Not applicable. 16. The best interest and permanent welfare of the child will be served by granting the relief requested because the child has lived with Plaintiff all of her natural life and does not know the Defendant as a father, other than after her birth, and has expressed rio interest in having any contact with his child. Further, the Plaintiff wishes to travel out of the country and needs to have supporting documents showing that she has primary physical custody of this child. WHEREFORE, Plaintiff requests the court to grant Plaintiff custody of the child. Respectfully submitted, SAIDIS, SNUFF, FLOWER & LINDSAY SAIDIS SNUFF, FLOWER & LINDSAY "1TfATNAW 26 W. Nigh Street Carlisle, PA Dated: lc- 2 -Z~ ) Johnn~. Ko ecky,/~squire Attorney I. # 53147 26 West High Street Carlisle, PA 17013 Attorney for Plaintiff verify that the statements made in the foregoing ~~~~~~, U~ are true and correct . I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904, relating to unsworn falsification to authorities. DATED : ~ ~ ( Q' rah Barone ~° CERTIFICAT SERVICE ,,1 On this ~ day of .1 ,~ u Q 20ts!i~ , I, hereby certify that I served a rue and correct copy of the foregoing Petition for Custody upon all parties of record via United States Mail, postage prepaid, addressed as follows: Lorenzo E. Archer, Jr. 1629 Derry Street Harrisburg, PA 17101 5 SAIDIS, CHUFF, FLOWER & LINDSAY n_n R5 ' 21 ± 1 : ? gqM IdSH 71,7-Sd7_-3d96 717-243-6486 SRlDJS SHLJFF MRSLRND yRRIFICATI0IQ . p.2 269 P12 JUL 06 '01 09:46 I verify that the statements made :in the fCregbing Petition Eor Emergency Relief are true and correct. I understand that false statements herein are made subject to the penalties oP 18 Pa c B ~ 49D4, relating to unsworn falsification to authorities. r~ DATED: ~" Q ah E: one SAIDIS SHUPT; Md1NrER ~ LINDSAY xb w. e[g~ euen CxMtble, NA CERTIFICATE O'' SERVICE ~--'1._. On this ~~ day of 20~, I, hereby certify that I served a true and correct copy of the foregoing Petition for Emergency Relief upon all parties of record via United States Mail, postage prepaid, addressed as follows: Lorenzo E. Archer, Jr. 1629 Derry Street Harrisburg, PA 17101 SAIDIS, SNUFF, FLOWER & LINDSAY 1 SAIDIS ~ SHUF$ FLOWER & LINDSAY By: r 2G W. High Street Carlisle, PA - z JUG ~ ~ 2,fl,~g~ SARAH E. BARONE, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY,PENNSYLVANIA V. N0.2001-3970 CIVIL TERM LORENZO E. ARCHER, JR., :CIVIL ACTION -LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, this ~ts~ day of 7' u ~ t,~ , 2001, upon consideration of the attached Custody Conciliation Rep , it is ordered and directed as follows: The prior Order of Court dated July 6, 2001 is hereby vacated. 2. Mother, Sarah E. Barone, shall have sole legal and primary physical custody of Jenna N. Archer-Barone, bom November 10, 1998. 3. Father, Lorenzo E. Archer, shall have periods of partial physical custody as the parties agree. cc: Johnna J. Kopecky, Esquire, counsel for Mother Lorenzo E. Archer, Jr., pro se 1629 Derry Street Harrisburg, PA 17104-3323 ~y,~ ~~ 1 BY THE COURT, 'm ~1UL ~ 5 ~~~if?~ SARAH E. BARONE, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY,PENNSYLVANIA V. :2001-3970 CIVIL TERM LORENZO E. ARCHER, JR., :CIVIL ACTION -LAW Defendant IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Jenna N. Archer-Barone November 10, 1998 Mother 2. A Conciliation Conference was held in this matter on July 25, 2001. The Mother, Sarah E. Barone, appeared with counsel, Johnna J. Kopecky, Esquire. Father, Lorenzo E. Archer, Jr., although aware of the conference, did not appear. 3. An Order of Court, dated July 6, 2001, was entered by the Honorable J. Wesley Oler, Jr. permitting Mother to take the child to Canada on vacation. 4. An Order in the form attached was requested by Mother. 'J-af o~ ~j•U Date acq line M. Verney, Esquire Custody Conciliator TAMIE AND ANTHONY STUMP, Husband And Wife Plaintiffs v. SALLY A. LEBO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-387n CIVIL TERM CIVIL ACTION -LAW JURY TRIAL DEMANDED TO THE PROTHONOTARY: PRAECIPE Please settle, withdraw and discontinue the above-captioned matter on behalf of the Plaintiffs, Tami and Anthony Stump. ~~$~®~ Date Respectfully Submitted TURD LAW OFFICES Ron Turo, Esquire 28 South Pitt Street Carlisle, PA 17013 (717)245-9688 Attorney for Plaintiffs C c. , _ . c.~ ~.i - n 2i ~'" rt.-- ~` _ ~': ., 'c-, ~° _i '°z t;! ` U7 ,~ - Nw3F•r -T"S.G~e y`k ..rta=tyF R3sS<:*.~yeeFnlfi.N~Yx~y!§Y~" fl:;:J.fli~M?P~agr?~f3?VSS.'~: .~. , . SARAH E. BARONS, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW LORENZO E. ARCHER, JR., NO. 2001-3970 CIVIL TERM Defendant IN CUSTODY ORDER OF COURT zoo f AND NOW this 3w~ day of 3 207 2965, the attached Custody Stipulation and Agreement is hereby made an Order of Court. cc: .Marylou Matas, Esquire Attorney for Plaintiff ~L'orenzo E. Archer, Jr., pro se b,~, 0 ~ 0 ~~~ r BY THE COURT, osc: s aaas '%~~~ ~' ~~' '>>~ a"'. c ~.1 b~ 8~ ~Ci l~?~ s,_. Pm~~i 93~l r ,-r i_ ~~;~~1!`li~~i SARAH E. BARONS, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW LORENZO E. ARCHER, JR., NO. 2001-3970 CIVIL TERM Defendant IN CUSTODY CUSTODY STIPULATION & AGREEMENT THIS STIPULATION AND AGREEMENT entered into the day and yeaz hereinafter set forth, by and between SARAH E. BARONS, (hereinafter referred to as "Mother") and LORENZO E. ARCHER, JR., (hereinafter referred to as "Father"). WHEREAS, the parties aze the natural pazents of one child, namely Jenna N. Archer- Barone, born November 10, 1998, (hereinafter referred to as "Child"); and WHEREAS, the parties live separate and apart, and wish to enter into a comprehensive stipulation and agreement relative to physical and legal custody of their Children. NOW THEREFORE, in consideration of mutual covenants, promises and agreements as hereinafter set forth, the parties stipulate and agree as follows: 1. Mother shall have sole legal custody of the child. 2. Mother shall have primary physical custody of the child. 3. Father shall have periods of visitation with the, child on the first Saturday of every month from 10:00 a.m. to 4:00 p.m., with said times being supervised by Mother. 4. In the event Father's Saturday visitation falls on a holiday or Mother's scheduled vacation time with the child, Father may exercise his visit on the very next Saturday following the holiday or vacation time. 5. The parties shall keep each other advised in the event of serious illness or medical emergency 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 parties shall have the right to visit the child as often as he or 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, 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 and affection for the other P~Y• 7. Any modification or waiver of any of the provisions of this Agreement on a permanent basis shall be effective only if made in writing, and only if executed with the same formality as this Stipulation and Agreement. 8. The parties desire that this Stipulation and Agreement be made an Order of Court of the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberland County does, in fact, have jurisdiction over the issue of custody of the parties' minor child. 9. The parties stipulate that in making this Agreement, there has been no fraud, concealment, overreaching, coercion, or other unfair deaiing on the part of the other party. 10. The parties acknowledge that they have read and understand the provisions of this Agreement. Each party acknowledges that the Agreement is fair and equitable and that it is not the result of any duress or undue influence. IN WITNESS WHEREOF, The parties hereto intending to be legally bound by the terms hereof, set forth their hands and seals the day and year hereinafter mentioned. WTTNESSETH: ~-~ ~. ~ Z ~ Dat Date COMMONWEALTH OF PENNSYLVANIA COUNTY OF ~D~-cc~ ~j~ sti On this o~CJ day of ~ieyn,~2~ 2005, before me, the undersigned officer, personally appeared SARAH E. BARONE, known to me (or satisfact~ proven) to be the person whose name is subscribed to the within Agreement and acknowledged that she executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ~ypA1M9NVJEALTH Of= RENNSYLVANIA NOTARIAL SEAL Not Public ELIZABETH A. GOWNLEY, Notary Pualic Clty of Hardeburg, Dauphin County My Commlasbn F~irea May 72, 2~7 COMMONWEALTH OF PENNSYLVANIA COUNTY OF ,QA~u~~i i,~t/ On this a~ day of ,OpGe~i 6~ ~ , 2005, .before me, the undersigned officer, personally appeared LORENZO E. ARCHER, JR., known to me (or satisfactory proven) to be the person whose name is subscribed to the within Agreement and acknowledged that he executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. t~ g~tylMldNiM€ALl ki q€ RIaNNSYLVANIA No Public NOTARIAL SEAL ELIZNBETH A. GOWNLEY, Notary PuYiic City of Hertlaburg, Dauphih Ooumy My Commlasion FaNires May 12, t~A07 ~ ~ c~ c. ~ -~ ~'~' =~„ ~~ ~~~ ?? a :\) "v ~~ - -c1 _._ "T3 "'t7 _ ('i1 f G? i~ a1 <_71 =< N ~~~'~~~ _'~._ wwrr~.. ~_... Mn~wawfsrw~.,'r~m+~m~rrya'xn.~a.:. .~p~.rr mr ,,,;: _~;,. ~: ..: ,. ...- .-~,: ,...:,.r=, z ;•e, +€zes~t~A!?,~.