HomeMy WebLinkAbout01-05062MARIE COOK and IN THE COURT OF COMMON PLEAS OF
RUSSEL COOK :CUMBERLAND COUNTY, PENNSYLVANIA
V.
CINDY L. QUEEN N0.2001-5062 CIVIL TERM
ORDER OF COURT
AND NOW, this 11TH day of SEPTEMBER, 2001, it appears to the court that the
stipulation contains insufficient information regarding the identity or whereabouts of the
natural father. Consequently, the parties are directed to join the natural father or to show
cause why he should not be joined pursuant to Pa. Rule of Civil Procedure 1915.6.
By the ,
Edward E. Guido, J.
Marie Cook
Russel Cook
213 Alters Road
Carlisle, Pa. 17013
Cindy Queen (~~n,'A
144 Lake Street - G-A- /~wO'-~- 9-//-0
Laconia, N.H. 03246
Stephanie E. Chertok, Esquire
61 West Louther Street
Carlisle, Pa. 17013
:sld
f , ~_
MARIE AND RUSSEL COOK,
PLAINTIFFS
v.
CINDY L. QUEEN,
DEFENDANT
AND NOW, this
s~~ ~ ~ zaa~ b~
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA
CIVIL TERM
IN CUSTODY O P ` 5O1n ~
ORDER OF COURT
day of
2001, Plaintiffs, Marie
Cook and Russel Cook and Defendant, Cindy L. Queen, having stipulated and agreed with regard
to custody of the child, KATILIN MARIE QUEEN, d.o.b. 6/30/90, it is hereby ordered and
decreed as follows:
Shared legal custody of the child, KATILIN MARIE QUEEN, shall be in both of
the parties.
2. Primary physical custody of said child shall be in the Plaintiffs, Marie Cook and
Russel Cook.
3. Defendant/mother, Cindy L. Queen, shall have such reasonable periods of
temporary partial custody/visitation as the parties may from time to time agree. The parties
further acknowledge and agree that the child's desire with regard to the extent and timing of any
such periods of partial custody/visitation shall be honored. At the present time, the periods of
partial custody for Defendant/mother shall include two months during the child's summer
vacation from school; one week during the child's Christmas vacation from school, if time
allows; and such additional periods of time during the child's other vacations from school, as the
parties may agree.
4. Plaintiffs agree not to seek child support at any time from Defendant/mother. In
exchange, mother surrenders her right to take the federal dependent's exemption and any child
credit for the child. Mother agrees to execute any IRS forms that may be required to accomplish
this provision.
Plaintiffs shall be permitted to authorize reasonable and necessary medical
treatment for the child during their periods of physical custody of her, and they shall be permitted
to place her on their health insurance coverage to the degree permitted by the insurance carrier.
J
6. Defendant/mother agrees to execute any and all forms required to enable Plaintiffs
to secure insurance coverage for the child and to enroll the child in a local school district.
7. All expenses of travel will be born by Defendant for those round trips required to
accomplish the periods of partial custody/visitation.
8. It is the intent of all parties that the child not be moved repeatedly as in prior years
and this Agreement shall not be modified unless and until careful consideration has been given to
the desires of the child in that regard.
BY THE COURT,
J.
._~ : _-.
MARIE COOK AND RUSSEL COOK,
PLAINTIFFS
v.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA
CIVIL TERM
CINDY L. QUEEN, IN CUSTODY ~ / .- J~o ~
DEFENDANT
STIPULAT N
AND NOW this C~ day of , 2001 come Plaintiffs,
Marie Cook and Russel Cook, of Carlisle, Pennsylvania, and Defendant, Cindy L. Queen, of
Pompano Beach, Florida, and with regard to custody of the Defendant's child, KATILIN MARIE
QUEEN, date of birth 6/30/90, stipulate and agree as follows:
Custody of said child shall be as set forth in the foregoing Order of Court, namely,
primary physical custody in Plaintiffs, who in effect are foster grandparents of the child, and
reasonable partial custodylvisitation in Defendant/mother.
2. It is the desire and intention of the parties hereto that this Stipulation for Child
Custody be entered in the Court of Common Pleas of Cumberland County, Pennsylvania, and
that it be endorsed as an Order of the Court so as to have the full effect thereof.
3. This Court shall retain jurisdiction should either party seek modification of the
Order in the future.
I verify that the statements made in the foregoing Stipulation are true and correct. I
understand that false statements herein are made subject to the penalty of 18 Pa. C.S. section
4904, relating to unsworn falsification to authorities.
DATE: ~~~
' /
WITNESS: ~ '
~~ ~~2Q~,~. Q ~lo~-~
Marie Cook, Plaintiff
a n' + i
I verify that the statements made in the foregoing Stipulation are true and correct. I
understand that false statements herein are made subject to the penalty of 18 Pa. C.S. section
4904, relating to unsworn falsification to authorities.
DATE:_1~~ ~
WITNESS: W •~5---~°
4--~~ ~
Russel Cook ,Plaintiff
I verify that the statements made in the foregoing Stipulation are true and con•ect. I
understand that false statements herein are made subject to the penalty of 18 Pa. C.S. section
4904, relating to unsworn f~aJlsification to authorities.
DATE: `~~/ mot/
WITNESS7/~~ ~
~ ~' 9 ~!
._~_
Q
,~
^~
rt~ `_ C~
_ V
I ~~
~_• -~ ~ ~j
R i~
' ~ IV_>
f S
~_ ~, .~ ~
",. - ~~ ~
~J
_~-.~. ~ ,w~xi ~~-a~ - ...
4
MARIE AND RUSSEL COOK,
PLAINTIFFS
v.
CINDY L. QUEEN,
DEFENDANT
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA
N0.2001-5062 CIVIL TERM
IN CUSTODY
~/ ORDER OF COURT
AND NOW, this ~ J ~ day of , 2003, Plaintiffs, Marie
Cook and Russel Cook and Defendant, Cindy L. Queen, having stipulated and agreed with regard
to custody of the child, KATILIN MARIE QUEEN, d.o.b. 6/30/90, it is hereby ordered and
decreed as follows:
Shared legal custody of the child, KATILIN MARIE QUEEN, shall be in both of
the parties.
2. Primary physical custody of said child shall be in the Plaintiffs, Marie Cook and
Russel Cook.
3. Defendant/mother, Cindy L. Queen, shall have such reasonable periods of
temporary partial custody/visitation as the parties may from time to time agree. The parties
further acknowledge and agree that the child's desire with regard to the extent and timing of any
such periods of partial custody/visitation shall be honored. At the present time, -the periods of
partial custody for Defendant/mother shall include two months during the child's summer
vacation from school; one week during the child's Christmas vacation from school, if time
allows; and such additional periods of time during the child's other vacations from school, as the
parties may agree.
~4. Plaintiffs agree not to seek child support at any time from Defendant/mother. In
exchange, mother surrenders her right to take the federal dependent's exemption and any child
credit for the child. Mother agrees to execute any IRS forms that may be required to accomplish
this provision.
~. Plaintiffs shall be permitted to authorize reasonable and necessary medical
treatment for the child during their periods of physical custody of her, and they shall be permitted
to place her on their health insurance coverage to the degree permitted by the insurance carrier.
6. Defendant/mother agrees to execute any and all forms required to enable Plaintiffs
to secure insurance coverage for the child and to enroll the child in a local school district.
7. All expenses of travel will be born by Defendant for those round trips required to
accomplish the periods of partial custody/visitation.
8. It is the intent of all parties that the child not be moved repeatedly as in prior years
and this Agreement shall not be modified unless and until careful consideration has been given to
the desires of the child in that regazd.
J.
C~
~;s
O 1-14-03
~~~`~~~,lzc~Jr'~J-~
~~~ .~
~c .4 .,., ~:..
vr~arE ,: r.,~r.~ ~ *. was~N3,t~'v~?s~~.~:s~u".a~~Ki , _
MARIE COOK and
RUSSEL COOK
Plaintiffs
v.
CINDY L. QUEEN
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
COMMONWEALTH OF PENNSYLVANIA
N0.2001-5062 CIVIL TERM
RESPONSE TO ORDER OF COURT TO
SHOW CAUSE
RESPONSE TO ORDER OF COURT TO SHOW CAUSE WHY THE NATURAL
FATHER SHOULD NOT BE JOINED IN THIS CUSTODY MATTER
PURSUANT TO PA. RULE OF CIVIL PROCEDURE 1915.6
1. On August 21, 2001, the parties stipulated to a custody arrangement for the
Defendant's natural child, KATILIN MARIE QUEEN, who was born June 30, 1990.
See Exhibit A; Exhibit B.
2. KATILIN MARIE QUEEN has known and been shown love and care by the
Plaintiffs, husband and wife, since her birth.
3. KATILIN MARIE QUEEN and the Defendant lived with the Plaintiffs for the first
three years of KATILIN MARIE QUEEN's life, on-and-off for the next two years of
her life, and since then the Plaintiffs have had many periods of custody of the child
when the Defendant would leave KATILIN MARIE QUEEN in their caze.
4. The Defendant, Cindy L. Queen, who resides at 806 Mulberry Drive, Martinsburg,
West Virginia, 25401, and the Plaintiffs, Mazie and Russel Cook, who reside at 213
Alters Road, Carlisle, Pennsylvania 17013, desire to have the Plaintiffs legally
designated as the child's primary custodians. Exhibit A.
5. On September 7, 2001, the parties requested this Court to enter a Custody Order
based upon the August 21 stipulation. See Exhibit C.
6. On September 11, 2001, this Court entered an Order directing the parties "to join the
natural father or to show cause why he should not be joined pursuant to Pa. Rule of
Civil Procedure 1915.6." See Exhibit D.
7. This Order was issued because the stipulation contained insufficient information
regarding the identity or whereabouts of KATILIN MARIE QUEEN' S natural father.
Exhibit D.
8. KATILIN MARIE QUEEN'S Certification of Birth shows that the Father's name
was not recorded. See Exhibit B.
9. The Defendant in this matter, Cindy L. Queen, KATILIN MARIE QUEEN' S natural
mother, now offers an affidavit to this Court to provide the identity and explain the
whereabouts of her daughter's natural father. Queen Affidavit attached as Exhibit E.
10. The "natural father is MARK SPOTTS [sic]". Queen Aff. (emphasis in original).
11. Mark Spotz knew that he was the father of KATILIN MARIE QUEEN, however
chose not to support, care for, or have contact with the child. Queen Aff.
12. Mark Spotz has evidenced a settled purpose of avoiding involvement in his
Daughter's life.
13. Additionally, Mark Spotz has been convicted of multiple homicides in this
Commonwealth resulting in three death sentences. Queen Aff.; Commonwealth v.
SpOYZ, 759 A.2d 1280 (Pa. 2000)(affirming the jury's verdict of guilty of first degree
murder and sentence of death for the killing of Betty Amstutz); Commonwealth v.
Snotz, 756 A.2d 1139 (Pa. 2000)(affinning the jury's verdict of guilty of first degree
murder and sentence of death for the killing of Penny Gunnet); Commonwealth v.
Snotz, 716 A.2d 580 (Pa. 1998)(affirming the jury's verdict of guilty of first degree
murder and sentence of death for the killing of June Ohlinger).
14. Mark Spotz also committed fratricide. Commonwealth v. Spotz, 759 A.2d 1280,
1285 n.6 (Pa. 2000)(stating Mark Spotz was convicted of involuntary manslaughter
for the slaying of his brother, Dustin Spotz) .
15. Mark Spotz has also been found guilty of two counts of kidnapping and various
crimes of violence. Commonwealth v. Spotz, 756 A.2d 1139, 1146 (Pa. 2000)(listing
the jury's convictions of first degree murder, kidnapping, robbery, theft, robbery of a
motor vehicle, and more); Commonwealth v. Spotz, 716 A.2d 580, 584 (Pa. 1998)
(listing the jury's convictions of first degree murder, aggravated assault, kidnapping,
robbery of a motor vehicle, and more).
16. Mark Spotz currently resides on Death Row. Interview with Records Office, State
Correctional Institution at Graterford, Tel. (610) 489-4151 (January 3, 2003).
17. In addition to his three death sentences, Mark Spotz has been sentenced to a minimum
of 35 years and 3 months in prison. Commonwealth v. Spotz, 756 A.2d 1139, 1146
(Pa. 2000)(reiterating the trial court's sentence for convictions of crimes related to the
first degree murder of Penny Gunnet as an aggregate consecutive term of 20 years and
9 months to 41 years and 6 months); Commonwealth v. Srootz, 716•A.2d 580, 584
(Pa. 1998)( reiterating the trial court's sentence for convictions of crimes related to
the first degree murder of June Ohlinger as fourteen and one-half to twenty-nine
yeazs of imprisonment to be served consecutive with the sentence imposed for the
slaying of Dustin Spotz).
18. The "position taken by the [R]ules [of Civil Procedure] is that ... a parent whose
parental rights have not been terminated [is a] necessary party to a custody
determination." Pa. Rule of Civil Procedure 1915.6 Explanatory Comment - 1994.
19. However, 23 Pa. C.S. §5303 (Award of custody, partial custody, or visitation)
requires a Court making a custody decision to consider a parent's criminal conviction
if found guilty of criminal homicide. 23 Pa. C.S. §5303(b)(1).
20.23 Pa. C.S. yc5303 also requires a Court making a custody decision to consider a
parent's criminal conviction if found guilty of kidnapping. 23 Pa. C.S. §5303(b)(2).
21. Moreover, the paramount and sole pertinent consideration in all custody
determinations regarding children is the best interest of the child involved. Garr v.
Garr, 2001 Pa. Super. 110, 773 A.2d 183, 187 (2001).
22. Mark Spotz, the natural father who chose not to support, care for, or have contact with
his child, KATILIN MARIE QUEEN, will be incarcerated well past KATILIN'S 47`"
birthday --assuming he survives three death penalties.
23. Mark Spotz is a danger to society and his daughter, K?.TILIN MARIE QUEEN.
24. KATILIN MARIE QUEEN is a twelve-yeaz old student in the Big Spring Middle
School, and has resided with Plaintiffs, husband and wife, since June 8~' of 2001.
25. ICATILIIJ MARIE QUEEN has been an honors and distinguished honors student the
past two years at Big Spring Middle School.
26. KATILIN MARIE QUEEN has an opportunity to spend her adolescent years with a
loving nurturing couple who aze eager to help her become a healthy member of
society, and who pose no threat to her safety or welfare.
WHEREFORE, Plaintiffs Marie and Russel Cook pray that this-Court enter the attached
Order that has been stipulated to by the parties.
BY: ~ v '
John C. Porter, Esq.
PA Sup. Ct. ID# 90152
Stephanie E. Chertok, Esq.
PA Sup. Ct. ID# 52651
Attorneys for Plaintiffs
61 W. Louther St.
Carlisle, PA 17013
717-249-1177
VERIFICATION
I verify that the statements made in this petition are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904
relating to unsworn falsification to authorities.
~ a~
Date
~Q/Lc.e, ~ 1,.~-/~
Plaintiff, Marie Cook
Exhibit A
iVIARIE COOK AND RUSSEL COOK,
PLAINTIFFS
v.
CINDY L. QUEEN,
DEFENDANT
IN THE COURT OF COMMON PLEAS
OF CUM$ERLAND COUNTY, PA
CIVII, TERM
IN CUSTODY
STIPULATLON
r ~
AND NOW this _ ~ ~~ day of '/ , ~(%~ ' 2UU 1 come Plaintiffs,
lvfarie Cook and Russel Cook, of Carlisle, Permsylvania, and Defendant, Cindy L. Queen, of
Pompano Beach, Plorida, and with regard to custody ofthe Defendant's child, ICATTLIN MARIE
QUEEN, date of birth 6r3Ui90, stinuiate and agree as follows:
Custody of said child shall be as set forth in the foregoing (:)rder of Court, namely,
primary physical custody in Plaintiffs, who in effect are foster grandpazents of the child, and
reasonable partial custodyivisitation in Defendantlmother.
2. It is the desire and intention of the parties hereto that this Stipulation for Child
Custody be entered in the Court of Common Pleas of` Cumberland County, Pennsylvania, and
that it be endorsed as an Carder of the f`ourt so as to have the full effect thereof.
3. °1'his Court shall retain jurisdiction should either parry seek modification of the
Order in the future.
1. verify that the statements made in the foregoing Sripulation are true and correct. I
understand that false statements herein are made subject to the penalty of i $ Pa. C.S. section
~19U4, relating to unsworn falsification to authorities.
DATE:-~~~~f•.~
WITNESS:
~~~Mari~e(C~oo~k, Plaintiff
I verify that the statements made in the foregoing Stipulation aze true and correct. 1
understand that false statements herein are made subject to the penalty of 18 Pa. C.S. section
4904, relating to unswom falsification to authorities.
DATE:_1~Lz`~
wITNESS:~~ W
~~ ~
Russel Cook ,Plaintiff
I verify that the statements made in the foregoing Stipulation aze true and correct. I
understand that false statements herein are made subject to the penalty of 18 Pa. C.S. section
4904, relating to unsworn falsification to authorities.
9 /~7~
DATE: ~~1 ~ v
/'
WITNESS:
Exhibit B
a~Two6-30-1990 ruE 0726610-1990
f+u.
' D0.TF 07-03-1990
• ' PaEO
- - •. P10. ON+ r(Nar
CcuRTroPCUMBERLAND oaT4 OB-03-2000
nlgTn - 16~E0
.. IMO.. pPr Y4RI
NAME - S£ii~' FEMALE
KATILIN HARIz. pU•EEN .~ -
FATHEt2S NAHE -, ,..-
INFORMinTIOl7•'`NOTr:'R£CQRDED
MOTETER5 MAIDEN NAME
CINDY T_EE'•••L1ifEEN ...
iymrR 10G111f9 NR11 WRy 1 rrV9 cY%CI [N01%pC YIrlL1119 Olr INY III IM11I'rvrrm9lVRnr9ORpR111M111 LI n W1111,
•+R4Vib4NVR 99110 Not 6R, P.4:fM. ROW AW py IM ORnLb Mumby. Vrrrr ]Y, •Yyy
f ~ ti~
:nPPIE`. +RRpL3fFP
frgf xEWCIRix x+%Cd IrtR PUwI
11707950 d
Exhibit C
;;~a Ci ? 20ii'~v`
MARIE AND RUSSEL COOK,
PLAINTIFFS
~.
CINDY L. QUEEN,
DEFENDANT
AND NOW, this
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA
CIVIL TERM
o/- SO~a
IN CUSTODY
ORDER OF COURT
day of
2001, Plaintiffs, Marie
Cook and Russel Cook and Defendant, Cindy L. Queen, having stipulated and agreed with regard
to custody of the child, ICATILIN MARIE QUEEN, d.o.b. 6/30/90, it is hereby ordered and
decreed as follows:
Shazed legal custody of the child, I{.4TILIN MARIE QUEEN, shall be in both of
the parties.
2. Primary physical custody of said child shall be in the Plaintiffs, Mane Cook and
Russel Cook.
Defendandmother, Cindy L. Queen, shall have such reasonable periods of
temporary partial custody/visitation as the parties may from time to time agree. The parties
further acknowledge and agree that the child's desire with regazd to the extent and timing of any
such periods of partial custody/visitation shall be honored. At the present time, the periods of
partial custody for DefendanUmother shall include two months during the child's summer
vacation from school; one week during the child's Christmas vacation from school, if time
allows; and such additional periods of time during the child's other vacations from school, as the
parties may agree.
4. Plaintiffs agree not to seek child support at any time from DefendanUmother. )n
exchange, mother surrenders her right to take the federal dependent's exemption and any child
credit for the child. Mother agrees to execute any IRS forms that may be required to accomplish
this provision.
5. Plaintiffs shall be permitted to authorize reasonable and necessary medical
treatment for the child during their periods of physical custody of her, and they shall be permitted
to place her on thew health insurance coverage to the degree permitted by the insurance carrier.
6. Defendantlmother agrees to execute any and all forms required to enable Plaintiffs
to secure insurance coverage for the child and to enroll the child in a local school district.
7. All expenses of travel will be born by Defendant for those round trips required to
accomplish the periods of partial custody/visitation.
It is the intent of all parties that the child not be moved repeatedly as in prior yeazs
and this Agreement shall not be modified unless and until careful consideration has been given to
the desires of the child in that regazd.
BY THE COURT,
J.
MARIE COOK AND RUSSEL COOK,
PLAINTIFFS
v.
CINDY L. QUEEN,
DEFENDANT
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA
CIVIL TERM
IN CUSTODY
STIPULATIAN
~ nF
AND NOW this C~ day of ~ , 2001 come Plaintiffs,
Marie Cook and Russel Cook, of Carlisle, Pennsylvania, and Defendant, Cindy L. Queen, of
Pompano $each, Florida, and with regazd to custody of the Defendant's child, KATILIN MARIE
QUEEN, date of birth 6/30/90, stipulate and agree as follows:
Custody of said child shall be as set forth in the foregoing Order of Court, namely,
primary physical custody in Plaintiffs, who in effect are' foster gr_andpazents of the child, and
reasonable partial custody/visitation in Defendant/mother.
2. It is the desire and intention of the parties hereto that this Stipulation for Child
Custody be entered in the Court of Common Pleas of Cumberland County, Pennsylvania, and
that it be endorsed as an Order of the Court so as to have the full effect thereof.
_ 3. This Court shall retain jurisdiction should either party seek modification of the
Order in the future.
I verify that the statements made in the foregoing Stipulation aze true and correct. I
understand that false statements herein are made subject to the penalty of 18 Pa. C.S. section
4904, relating to unswom falsification to authorities.
DATE:-~~~
WITNESS:
Marie Cook, Plaintiff
,,
I verify that the statements made in the foregoing Stipulation aze true and convect. I
understand that false statements herein are made subject to the penalty of 18 Pa. C.S. section
4904, relating to unswom falsificadotr to authorities.
DATE:~
WITNESS: \~o ~.~7.
Russel Cook ,Plaintiff
I verify that the statements made in the foregoing Stipulation aze true and correct. I
understand that false statements herein are made subject.to the penalty of 18 Pa. C.S. section
4904, relating to unsworn falsification to authorities.
DATE: `~~ ~ v?~
WITNESS: /' `
Exhibit D
~ ea . ..
MARIE- COOK and : IN THE COURT OF COMMON PLEAS OF
RUSSEL COOK :CUMBERLAND COUNTY, PENNSYLVANIA
V.
CINDY L. QUEEN N0.2001-5062 CIVIL TERM
ORDER OF COURT
AND NOW, this 11TH day of SEPTEMBER, 2001, it appears to the court that the
stipulation contains insufficient information regarding the identity or whereabouts of the
natural father. Consequently, the parties are directed to join the natural father or to show
cause why he should not be joined pursuant to Pa. Rule of Civil Procedure 1915.6.
By the ,
Edward E. Guido, J.
Marie Cook
Russel Cook
213 Alters Road
Cazlisle, Pa. 17013
Cindy Queen
144 Lake Street
Laconia, N.H. 03246
Stephanie E. Chertok, Esquire
61 West Louther Street
Carlisle, Pa. 17013
:sld
Ifl TBS.itEiOWy vdhB~9af, I heie ut'iYC 55i mj' hiaRd
and the seal az sai~ Cass, at Catlis~e, Pa.
This ~' day~_~c~t?`"w~"'.r~2L
Prothoria 9
4 ,
Exhibit E
~ 4
W e .
717+249+4514 P.02
MAItU~, Cflt)K AND RUSSEL COOK, IN THE COURT OF COMMON 1'1.F,AS
I'LAINTIFp'S , OF CUMIIEIt.I.ANA CQUNTY, l'A,
v. No. QI-5062 CIVII. TERM
CilYilY I,. QUF,F.'N, IN CUSTODY
DEFENDANT
AFFIDAVIT
l3cfore me, i}ae undersigned authority. a Notary Public, in and €'or the said County and
State, personally appeared CINDX L. QUEEN, known to me (or satisfactorily proven), wlxt,
axing duly sworn. according to law, deposes and says that she is the Defendant in the abave-
captioncd custody stipulation proceeding; that she is the natural mother of KAT[L[N Mt1R[[i
Q[JN.IiN, d.o.b. 6130190, wha is the subject of said custody stipulation; that the natural f'athcr is
MARK 51't)'I"I'S, who has been convicted ofmultiple crimes and homicides in the
t'ommonwcalth of Pennsylvania and who is incarcerated in Pennsylvania for these crimes attd, to
the best M' her knowledge, received a death sentence for one homicide.
Deponent further says that she attd KATIL[N MARIE QUEEN have had no contact with
MARK SPt)"I°I'S for years; that MARK SPt?TTS is not involved and never has been involved in
the care or support of KATILIN; and that this was by his choice, [n that he did know that he was
KA'fl1,.iN'S father.
,',
_ SL; ,}
DY L ~ EEN -..~
STATE OF I,uEST U 1(Z6-(N l~
COL]L\1'C~ OF S3E12KEl.Cy
$wum to and subscribed before me / ivl y commission~c ire5 ra't~ 2(707,
this day of ~ f~-Y1 r ,
rtvratrr Pue~tc
'Jt)t)~ smrEOrwESrwamnna
Q / ~7~~^~//)J ~ ~~ ~y{~ ~ / //7~ ~4iAMM~RStA
..~~s~~~J/G.~1'"'yl `~~~ ~N ~ Q _. _701 M¢8T
1ti104'!ry t'nbllc
• .
.~;~
.~
~-, ~._,
~;; '.
__
~' ,n
_-- - .,,
~~
- oa:2~zw e .~'~"-~ i ,•.• -,.::• '??K'i~ewE:~gx P~fL§„qR*t?nu"'4'+ein.~mvn,~~YYrmeeP'tm:...