HomeMy WebLinkAbout01-04242,,
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'~JUL Y 2 20Di~
1N THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
IN RE: ~ esa"~- ~eCG U5, CIVIL
~n~ i'Yi• ~.ercho.~
ACTION NO. f7/- y~Y~- ~"`~ '``""
ORDER OF COURT
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AND NOW, this~day of q~ 2001, upon consideration of the
attached Custody Stipulation, it is hereby ordered that Ann Kerchoff shall
have full, legal and physical custody of the Micheal A. Reed and Arthur J.
Lincoln V.
BY THE COURT, '/
.
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Teresa M. Reed
1950 Simpson Ferry Road
Mechanicsburg, PA 17055
PLAINTIFF
Ann Kerchoff
PO Box 428
North Main Street ,~.~
Herndon, PA 17830
DEFENDANT
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
IN RE: ~~-~5~ ~• ~Ke~,~,~..`Sf~ /~n CIVIL
ACTION
Micheal A. Reed and Arthur J. Lincoln V NO:
CUSTODY STIPULATION
It is hereby stipulated that:
1. Teresa M. Reed, natural mother of herein named minor, is an adult
individual who currently resides at 1950 Simpson Ferry Road
Mechanicsburg, PA 17055.
2. Arthur Lincoln III, natural father of herein named minor, is an adult
individual whose whereabouts currently are unknown. Arthur's last
known address was 1950 Simpson Ferry Road Mechanicsburg, PA
17055. Daniel Reed, natural father of herein named minor, is an adult
individual whose whereabouts currently unknown. Daniel's last known
address was 177 Wallace Blvd. Clarksville, TN 37042.
Arthur J. Lincoln V, minor and natural child of Teresa M. Reed and
Arthur Lincoln III, currently resides at PO Box 428 North Main Street
Herndon, PA 17830. Micheal A. Reed, minor and natural child of
Teresa M. Reed and Daniel Reed, currently resides at PO Box 428
North Main Street Herndon, PA 17830.
4. Ann Kerchoff, the step mother of Teresa M. Reed, is an adult who
currently resides at PO Box 428 North Main Street Herndon, PA
17830.
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5. Teresa M. Reed has full, legal, and physical custody of Micheal A.
Reed and Arthur J. Lincoln V. Teresa M. Reed wishes to give custody
of Micheal A. Reed and Arthur J. Lincoln V to Ann Kerchoff. Ann
Kerchoff will have full, legal and physical custody of Micheal A. Reed
and Arthur J. Lincoln V, including the right and responsibility to make
decisions regarding Micheal and Arthur's education, health, financial
and any other decision that may be required to properly care for said
minor.
6. Ann Kerchoff wishes to accept full, legal and physical custody of
Micheal A. Reed and Arthur J. Lincoln V.
7. There is no requirement for Teresa M. Reed to pay child support in any
manner or form.
Respectfully Submitted:
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to
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Date
Name Teresa M. Reed
Name Ann Cerchoff ~'v
NOTARIAL SEAL
ROBERT J. GOLD, Notary Public
Hampden Twp. Cumberland County
My Commission Expires July 30, 2003
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IN RE: TERESA M. REED
vs
ANN M. KERCHOFF
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
NO: 01-4242 CIVIL
CUSTODY
ORDER OF COURT
AND NOW, this dL day of March, 2003, upon consideration of the attached
petition and by agreement of the parties, the following Order is entered regarding
custody of Michael A. Reed and Arthur J. Lincoln, V:
Plaintiff, Teresa M. Reed, shall have sole physical and legal custody of
the children.
This Court relinquishes jurisdiction of the custody case; any further
custody matters should be filed where the children reside.
BY THE CO~
,~
Ke m A. Hess, Judge
This/O~rd~er~is a^nte_red pursuant,,t~fo the consent of the Plaintiff and T)efendant:
cam-i""""'0. y y~ - ~ V`
Teresa Reed, Pl'aint`iff nn Kerchoff, ro se Defendant
J an Carey, Attorney for intiff
Distribution:
Joan Carey, Attorney for Plaintiff
MIDPENN LEGAL SERVICES
8 Irvine Row
Carlisle PA 17013
Ann Kerchoff, pro se Defendant
P.O. Box 428
North Main Street
Herndon, PA 17830
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(_ P~A~[PAIIM~flL~A~L _ _.. _ ~ :.. '. ~h%' P 1 s_ .3i-: f3lMI'~-.' 6
IN RE:
TERESA M. REED IN THE COURT OF COMMON PLEAS
vs OF CUMBERLAND COUNTY
ANN M.KERCHOFF
NO: 01-4242 CIVIL
CUSTODY
P~-TIT'^''''T.~IFY CUSTODY ORDER
Plaintiff, Teresa M. Reed, by and through her attorney, Joan Carey of MidPenn
Legal Services states the following:
Plaintiff, Teresa M. Reed, hereinafter referred to as the mother, currently
resides at 316 Apartment J, Boulder Drive, Newport News, Virginia,
23608.
2. Defendant, Ann M. Kerchoff, who is the stepmother of the
plaintiff/mother, Teresa Reed, currently resides at P.O. Bos: 428, North
Main Street, Herndon, Pennsylvania, 17830.
3. Arthur Lincoln, III, is the natural father of the minor child, Arthur J.
Lincoln; the natural father's whereabouts are unknown to the mother and
his last known address was 1950 Simpson Ferry Road Mechanicsburg,
Pennsylrania17055.
4. Daniel Reed, is the natural father of the minor child, Michael A. Reed; to
the best of the mother's knowledge he last resided in Georgia at an address
unknown to her, and he is currently in the military in Kuwait.
5. An Order of Court was entered on July 13, 2001, in the above captioned
case granting Defendant legal and physical custody of the mother's minor
children, Michael A. Reed and Arthur J. Lincoln, V.
6. Defendant returned the children to the custody of their mother on or about
February 23, 2002, and they have resided with their mother since that
time.
The mother requests that the Order of July 13, 2001, be modified to
confirm the status quo of custody in the mother.
8. The mother further requests that the court relinquish jurisdiction of the
case, and order that any further matters regarding custody be brought
where the children reside.
The parties are in agreement and wish to have an Order entered consistent
with the above terms and pursuant to their signed consent.
WHEREFORE, the Plaintiff/mother requests that the court enter an Order
granting her sole physical and legal custody of her children.
Respectfully submitted,
f r.
~ oan Carey, Attorney r Plaintiff
MidPenn Legal Servtces
8 Irvine Row
Carlisle PA 17013
VERIFICATION
The above-named Plaintiff, Teresa M. Reed, verifies that the statements made in the
above Petition are true and correct. Plaintiff understands that false statements herein are made
subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification. to authorities.
Date: o?~ / /~L~~` ~~ <~.; Ct`~ - V`
Teresa M. Reed, :Plaintiff
'I;~IUL ~ ~ 2a6~~ . .
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
IN RE: ~ ~5~~~' `e~I U5~ CIVIL
ACTION NO. c~ / - ~l ~ v~1- ~~x~ '``~"
ORDER OF COURT
i?'
AND NOW, this~day of q+~y 2001, upon consideration of the
attached Custody Stipulation, it is hereby ordered that Ann KE:rchoff shall
have full, legal and physical custody of the Micheal A. Reed aind Arthur J.
Lincoln V.
BY THE COURT,
`.~
Teresa M. Reed
1950 Simpson Ferry Road
Mechanicsburg, PA 17055
PLAINTIFF
Ann Kerchoff
PO Box 428
North Main Street ~..e,~~~
Herndon, PA 17830
DEFENDANT
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
IN RE: ~p-~oS~,(, ~ ~N=/~~~ ~`s° /~~ CIVtL
ACTION
Micheal A. Reed and Arthur J. Lincoln V NIO:
CUSTODY STIPULATION
It is hereby stipulated that:
Teresa M. Reed, natural mother of herein named minor, is an adult
individual who currently resides at 1950 Simpson Ferry Road
Mechanicsburg, PA 17055.
2. Arthur Lincoln fil, natural fiather of herein named minor, is an adult
individual whose whereabouts currently are unknown. Arthur's last
known address was 1950 Simpson Ferry Road Mechanicsburg, PA
17055. Daniel Reed, natural father of herein named minor, is an adult
individual whose whereabouts currently unknown. Daniel's fast known
address was 177 Wallace Blvd. Clarksville, TN 37042.
Arthur J. Lincoln V, minor and natural child of Teresa M. Reed and
Arthur Lincoln III, currently resides at PO Box 428 North Main Street
Herndon, PA 17830. Micheal A. Reed, minor and natural child of
Teresa M. Reed and Daniel Reed, currently resides at PO Elox 428
North Main Street Herndon, PA 17830.
4. Ann Kerchoff, the step mother of Teresa M. Reed, is an adult who
currently resides at PO Box 428 North Main Street Herndon, PA
17830.
5. Teresa M. Reed has full, legal, and physical custody of Micheal A.
Reed and Arthur J. Lincoln V. Teresa M. Reed wishes to give custody
of Micheal A. Reed and Arthur J. Lincoln V to Ann Kerchotfi. Ann
Kerchoff will have full, legal and physical custody of Mich<;al A. Reed
and Arthur J. Lincoln V, including the right and responsibility to make
decisions regarding Micheal and Arthur's education, health, financial
and any other decision that may be required to properly care for said
minor.
6. Ann Kerchoff wishes to accept full, legal and physical custody of
Micheal A. Reed and Arthur J. Lincoln V.
7. There is no requirement for Teresa M. Reed to pay child saappork in any
manner or form.
Respectfully Submitted:
to
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Name Teresa M. Reed
Date
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Name Ann <erchoff
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EtOBEFiT J. GOLD, Notary
t4ampdun i~~>p. Curr6arlat}rJ C~~unry
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IN RE: TERESA M. REED
vs
ANN M. ICERCHOFF
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
NO: 01-4242 CIVIL.
CUSTODY
AFFIDAVIT OF SERVICE
I, Sat1d ra ~ . ~o wer ~ ,the undersigned, hereby state that I served
a copy of the Petition to Modify Custody Order upon the Defendant by handing the
papers to ~r\n ~1P Y CrO-~-~ (~,~ at the following address:
f ~ 7 ~Ou~-tn ~ ~~~ S+. SIIn~IU~v, fi~4- l1~ ~ on the ~ day
of NIarCJ~l , 2003, at approximately ~_ o'clock~.m.
I verify that the statements made in this Affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
§4909, relating to unsworn falsification to authorities.
Name: ~'~ ra H .1"l1bZU~r
Address:%Qr/ oSD.II~~•~l~nbur~.~P~I~tb'61
Dated: ~~-c~O-C1:3
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IN RE:TERESA M. REED
vs
ANN M.KERCHOFF
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
NO: 01-4242 CIVIL
CUSTODY
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow Teresa M. Reed, Plaintiff, to proceed in forma pauperis:
I, Joan Carey, attorney for the party proceeding in forma pauperis, certify that I
believe the party is unable to pay the costs and that I am providing free legal service to
the party.
MIDPENN LEGAL SERVICES
8 Irvine Row
Carlisle, PA 17013
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tit<orney ror riamnrr
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IN RE: TERESA M. REED IN THE COURT OF COMMON PLEAS
vs OF CUMBERLAND COUNTY
ANN M. KERCHOFF
NO: 01-4242 CIVIL
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CUSTODY -~,``~: _ -
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ACCEPTANCE OF SERVICE ~i ''~ ~
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I, Ann Kerchoff, Defendant in the above captioned custody case, accept servic~f fn
the Petition to Modify Custody Order.
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Ann M. Kerchoff, efendant
Address: ~~ ppX day
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