HomeMy WebLinkAbout99-03763i
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
A •
Jenifer A. Morrison,
Plaintiff \'tt,,,_99-3763 ... XJ9
David W. Morrison,
Defendant
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DECREE IN
DIVORCE
AND NOW,.. .1?...1,...... x .1'YlA it is ordered and
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decreed that .....Jenifer.A..Morrison .........................• plaintiff,
and .............. Dayid, K.. Morrison, ........................ , 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; "V OA"
The ,Pro.Perty settlement Agreement .3,S incorporated .but not merged.into... .
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decree.
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THIS IS AN AGREEMENT made this 91b- day of 1)e iY ?D ,i , 2000, by and
between David W. Morrison, of 1233 Crottlestown Road, Chambershurg, Franklin County,
Pennsylvania, (hereinafter referred to as Husband) and Jenifer A. Morrison, of 72 Marsh Drive,
Carlisle, Cumberland County, Pennsylvania, (hereinafter referred to as Wife).
WHEREAS, Husband and Wife were married on November 16, 1996, in Cumberland County,
Pennsylvania; and
WHEREAS, various differences have arisen between Husband and Wife, whereby they have
been living separate and apart since December 31, 1993; and
WHEREAS, the parties have agreed to maintain separate and permanent domiciles and to live
apart from each other; and
WHEREAS, the parties desire to enter intc, an amicable settlement to provide for all of the
property rights of the parties and to dispose of the rights and obligations of each to the other in
respect to support, maintenance, alimony, counsel fees, equitable distribution, and all other rights
and obligations under the Divorce Code of 1930, as amended, and it is the intention and
agreement of the parties that this Agreement be a full, complete and final settlement of all of
those rights and obligations under said Divorce Code; and
NOW, THEREFORE, for and in exchange of mutual considerations, and intending to be bound
by the provisions hereof, the parties agree that their recitals form a part of this Agreement and
waive any right to counseling under the Divorce Code of 1980, as amended, and right to counsel
fees, costs, alimony, support, maintenance, and any other rights under the said Divorce Code not
provided for herein and agree as follows:
1. SEPARATION. The parties agree that it shall he lawful for each party, at all times
hereafter, to live separate and apart from the other, at such place or places as he or she may, from
time-to-time, choose or deem fit. Each party shall be free from interference, authority or contact
by the other, as fully as if he or she were single and unmarried, except as may be necessary to
carry out the provisions of this Agreement and as may be necessary to exchange information that
pertains to the parties' minor child. Neither party shall molest the other or attempt to endeavor to
molest the other, nor compel the other to cohabit with the other, or in any way harass or malign
the other, nor in any way interfere with the peaceful existence, separate and apart, from the other.
2. AUTOMOBILES. Husband shall have as his sole and exclusive property, title to and
possession of the 1994 Toyota Pickup. Wife shall have as her sole and exclusive property, title
to and possession of the 1992 Honda Accord. Wife shall be responsible fir any fees tier the
defaulted lease on the 1997 Toyota Corolla. Each party shall indemnify and hold the other
harmless from and liability on any loan encumbering the vehicle, cost of repairs, maintenance,
registration, insurance and/or inspection of the vehicle which each is taking as his/her sole and
exclusive property.
3. PERSONAL PROPERTY. The parties have divided or have agreed to a division of their
personal property which includes bank accounts, certificates of deposit, life insurance policies,
jewelry, clothing, fumiture and other personal items. After the aforesaid division of the personal
property is complete, any and all property in the possession of Husband shall be his sole and
separate property. Any and all property in the possession of W itc shall be her sole and separate
property. Each party forever renounces whatever claims he/she may have with respect to the
property which the other is taking. Each party understands that he/she has no right or claim to any
property acquired by the other after the signing of this Agreement.
4. PENSION/RETIREMENT PLANS. Wife hereby releases any and all claims or demands
she may have on Husband's pension or retirement plans. Husband hereby releases any and all
claims or demands he may have on Wife's pension or retirement plans.
5. DEBTS. Wife shall be responsible for any outstanding medical bills that she incurred
during the marriage. The parties represent and warrant to each other that neither has incurred any
other debts nor made any other contracts for which the other or his/her estate may be liable, from
date of separation forward. Neither party shall contract nor incur any debt or liability for which
the other or his/her property or estate might be responsible and agrees to indemnify the other
from any claims made against the other because of debts/obligations not incurred by the other.
6. ALIMONY, ALIMONY PENDENTE LITE, SUPPORT OF SPOUSE. The parties waive
any and all right to receive from the other any payment of alimony, alimony pendente lite, and/or
spousal support.
7. CHILD SUPPORT. Husband shall have insurance coverage for the parties' minor child at
all times. Wife shall receive $300.00 monthly from Husband for support for the minor child.
8. EFFECTIVE DATE. The effective date of this Agreement shall be the date of execution
by the parties if they had each executed the Agreement on the same date. Otherwise, the
execution date of this Agreement shall be defined as the date of execution by the party last
executing this Agreement.
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9. DIVORCE. A Complaint in Divorce, claiming that the marriage is irretrievably broken
under the no-fault mutual consent provision of'Section 3301(c) of the Pennsylvania Divorce
Code, was filed with the Prothonotary of Cumberland County on June 22, 1999. Both parties
agree to execute any and all affidavits or other documents necessary fin- the parties to obtain an
absolute divorce pursuant to Sections 3301(c) of the Divorce Code including waiver of all rights
to request Court ordered counseling.
10. INCORPORATION INTO DECREE. Should a decree, judgment or order of separation
or divorce be obtained by either of the parties in this or any other state, country, or jurisdiction,
each of the parties hereby consents and agrees that this Agreement and all of its covenants shall
not be affected in any way by any such separation or divorce; and that nothing in any such decree,
judgment, order or further modification and revision thereof shall alter, amend or vary any term
of this Agreement, whether or not either or both of the parties shall remarry, it being understood
by and between the parties hereto that this Agreement shall survive and shall not be merged into
any decree, judgment, or order of divorce or separation. It is specifically agreed, however, that a
copy of this Agreement or the substance of the provisions thereof, may be incorporated by
reference into any divorce, judgment or its decree. This incorporation, however, shall not be
regarded as a merger, it being the specific intent of the parties to permit this Agreement to
survive anyjudgment and to be forever binding and conclusive upon the parties.
IL MUTUAL RELEASE. Husband and Wifc do hereby mutually remise, release, quit claim
or forever discharge the other and the estate of such other, for all time to come, and for all
purposes whatsoever, from any and all rights, title and interest, or claims in or against the estate
of such other, of whatever nature and wherever situate, which he or she now has or at anytime
hereafter may have against such other, the estate of'such other or any part thereof, whether
arising out of any former acts, contracts, engagements or liabilities of such other or by way of
dower or curtesy of claims in the nature of dower or curtesy, or widow's or widower's rights,
family exemption or similar allowance or under the intestate laws; or the right to take against the
spouse's will; or the right to treat a lifetime conveyance by the other as testamentary or all or
other rights of the surviving spouse to participate in a deceased spouse's estate, whether arising
under the laws of Pennsylvania, any state, commonwealth or territory of the United States, or any
other country or any right which either party may now have or at anytime hereafter have for past,
present or future support or maintenance, alimony, alimony pendente lite, counsel tees, costs or
expenses, whether arising as a result of the marital relation or otherwise, except and only except
all rights and agreements and obligations of whatsoever nature arising or which may arise under
this Agreement or for the breach of any provision thereof. It is the intention of Husband and Wife
to give to each other by the execution of this Agreement a full, complete and general release with
respect to any and all property of any kind or nature, real, personal or mixed, which the other
now owns or may hereafter acquire, except and only except all rights and agreements and
obligations of whatsoever nature arising or which may arise under this Agreement or for the
breach of any provision thereof.
12. COUNSEL FEES. Each party individually covenants and agrees that he or she will
individually assume the full and sole responsibility fbr legal expenses for his or her attorney and
court costs in connection with any divorce action which may be brought by either party and shall
make no claim against the other for such costs or fees.
13. 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 or documents that may be reasonable required to give full force and effect to the
provisions of this Agreement.
14. MODIFICATION OR WAIVER. A modification or waiver of any of the provisions of
this Agreement shall be effective only if made in writing and executed with the same formality as
this Agreement. The failure of either party to insist upon the strict performance of any of the
provisions of this Agreement shall not be construed as a waiver of any subsequent default of the
same or similar nature.
15. 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.
16. SEPARATE PARAGRAPHS. It is specifically understood and agreed by and between
the parties thereto that each paragraph hereof shall be deemed to be a separate and independent
agreement.
17. BREACH. If either party breaches any provision of this Agreement, the other party shall
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 Agreement shall
be responsible for payment of legal fees and costs incurred by the other in enforcing the rights
under this Agreement, or in seeking such other remedies or relief as may be available to him or
her.
18. CONTROLLING LAW. This Agreement shall be construed under the laws of the
Commonwealth of Pennsylvania.
19. INVALIDITY OF PROVISIONS. If any term, condition, clause or provision of this
Agreement shall be determined or declared to be void or invalid in law or otherwise, then only
that term, condition, clause or provision shall be stricken from this Agreement, and, in all other
respects, this Agreement shall be valid and continue in full force, effect and operation.
20. BINDING NATURE. Except as otherwise set forth herein, this Agreement shall be
binding and shall inure to the benefit of the parties hereto and their respective heirs, executors,
administrators, successors and assigns.
IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year
first above written.
WITNESS
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David W. Morrison
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
On this °? 1 day of 2000, before me personally
appeared David W. Morrison, to me k wn to be the person described in and w
executed the foregoing instrument, and acknowledged that he executed the me as
his free act and deed.
Notary Public
NOTARIAL SEAL
CLARE R. ELDER, Notary Public
Chambersburg, Franklin COUnry
My Commission Expires Jan.9, 2001
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
On this l> T'? day of ! 1) V e uLa)> , 2000, before me personally
appeared Jenifer A. Morrison, to me known to be the person described in and who
executed the foregoing instrument, and acknowledged that she executed the same as
her free act and deed. /
n I IAR A Jza--4?
Notary Public
Nntarlal Seal
Niven J. Ravd, Not?.ry Public
Corlisla Roro, Cumberlantl County
My Commission E, "a' Nov. 2, 212
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JENIFER A. MORRISON,
Plaintiff
V.
DAVID W. MORRISON
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
CIVIL DIVISION - LAW
NO. 99- 3763 CIVIL TERM
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 3301(c) of the Divorce Code.
2. Date and manner of service of the Complaint: Certified and Return receipt requested, June
24, 1999.
3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code:
By Plaintiff: November 8, 2000; by Defendant: November 8, 2000.
4. Related claims pending: None
5. Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the
Prothonotary: 13 tXi
Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the
Prothonotary: I I , 13 .6"b
2indsa?y Dar aird, Esquire
Attorney for the Plaintiff
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JENIFER A. MORRISON,
Plaintiff
V.
DAVID W. MORRISON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
NO.99-,3?63 CIVIL TERM
: IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You 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 warned that if you fail to do so, the case may proceed
without you and a decree of divorce or annulment 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 grounds for divorce is indignities or irretrievable breakdown of the marriage, you may
request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office
at the Cumberland County Courthouse, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION 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 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
TELEPHONE: (717) 249-3166
JENIFER A. MORRISON,
Plaintiff
V.
DAVID W. MORRISON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
NO. 99- CIVIL TERM
IN DIVORCE
COMPLAINT UNDER SECTION 3301(C) OR (D)
OF THE DIVORCE CODE
Plaintiff, Jenifer A. Morrison, by her attorney, Lindsay D. Baird, Esquire, sets forth the following:
Plaintiff, Jenifer A. Morrison, is an adult individual residing at 72 Marsh Drive, Carlisle,
Cumberland County, Pennsylvania 17013.
2
Defendant, David W. Morrison, is an adult individual residing at 1283 Crottlestown Road,
Chambersburg, Franklin County, Pennsylvania 17201.
3
The parties were married on November 16, 1996 in Cumberland County, Pennsylvania..
4
Plaintiff and Defendant have lived continuously in the Commonwealth of Pennsylvania for at least
six months prior to the commencement of this action.
5
This action is not collusive.
6
There have been no prior actions for divorce or annulment in this or any other jurisdiction within the
knowledge of the Plaintiff.
In accordance with Section 3301(c) of the Divorce Code, the marriage between the parties is
irretrievably broken.
Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request
that the Court require the parties to participate in counseling.
WHEREFORE, the Plaintiff requests your Honorable Court to decree that the Plaintiff be divorced
from the Defendant.
dsay D. Bair , quire
Attorney for th aintiff
37 S. Hanover Street
Carlisle, PA 17013
717 - 243-5732
I verify that the statements in the foregoing pleading are true and correct. I understand that false
statements herein are made subject to the penalties of 18 PaCS 4904 relating to unswom falsification
to authorities. I r A n n
J?nifer A. Morrikon
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JENIFER A. MORRISON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
V. : CIVIL DIVISION - LAW
DAVID W. MORRISON NO. 99- 3763 CIVIL TERM
Defendant
IN DIVORCE
AFFIDAVIT OF SERVICE
I, Lindsay Dare Baird, Esquire, being duly sworn according to law do depose and state that a
copy of the Complaint filed in the above-captioned matter along with a copy of a Notice to Plead
and a Notice of Availability of Marriage Counseling was served on the Defendant, June 24,
1999, by Certified Mail - Return Receipt Requested, restricted delivery, a copy of said return
receipt evidencing delivery being attached hereto. Said service on June 24, 1999.
Li dsay D. Bai d squir
Itomey for Plaintiff
37 South Hanover Street
Carlisle, PA 17013
717 - 243-5732
Sworn and Subscribed to
before me this g*a day
of NVeWUA , 2000.
Notary Public
Notarial Seal
lJlven J. Baird, Not=ry Public
t ar{ielo Boro, Cumberlano Gou2ttye2
+d? Compassion Expires Nov. 2,
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Jcnifcr A. Morrison, IN THE COURT OE COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
V. NO. 99- 3703 CIVIL TERM
David W. Morrison, : IN DIVORCE
Dcfcndant
AFFIDAVIT OF CONSENT, ACCEPTANCE OF SERVICE
AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE
DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE
1. A complaint in divorce under Section 3301(C) of the
Divorce Code was filed on June 22, 1999.
2. Defendant acknowledged receipt and accepted service of
the Complaint on June 24, 1999.
3. The marriage of the Plaintiff and Defendant is
irretrievably broken and ninety days have elapsed from the date
of the filing of the Complaint.
4. I consent to the entry of a final decree in divorce
without notice.
5. 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.
6. 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 immediately after it is filed with the
Prothonotary.
7. I have been advised of the availability of marriage
counseling and understand that I may request that the Court
require counseling. I do not request that the Court require
counseling.
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. Section 4904 relating to
unsworn falsification to authorities.
Date: II U 4A
e ifer A. M rrison, Plaintiff
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Jcnifcr A. Morrison, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
V. NO. 99- 3763 CIVIL TERM
David W. Morrison, IN DIVORCE
D&ndant
AFFIDAVIT OF CONSENT, ACCEPTANCE OF SERVICE
AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE
DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE
1. A complaint in divorce under Section 3301(C) of the
Divorce Code was filed on June 22, 1999.
2. Defendant acknowledged receipt and accepted service of
the Complaint on June 24, 1999.
3. The marriage of the Plaintiff and Defendant is
irretrievably broken and ninety days have elapsed from the date
of the filing of the Complaint.
4. I consent to the entry of a final decree in divorce
without notice.
5. 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.
6. 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 immediately after it is filed with the
Prothonotary.
7. I have been advised of the availability of marriage
counseling and understand that I may request that the Court
require counseling. I do not request that the Court require
counseling.
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. Section 4904 relating to
unsworn falsification to authorities.
Date: w C?-t I-,-
David W. Morrison, Defendant
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JENIFER A. MORRISON
Plaintiff
V.
DAVID W. MORRISON,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
No. 99- 3?63 CIVIL TERM
: IN CUSTODY
ORDER AND NOTICE
AND NOW, TLtilE a ti, 1999, upon consideration of the attached
complaint, it is hereby dir ted that the parties and their respective counsel appear
before Y. C' the conciliator,
at "h b r on the day
of ,1999, at j " J L m., for a Pre-Hearing Custody Conference. At such
co erence, 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.
FOR THE COURT,
By' I I
Custody Conciliato r?J
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
TELEPHONE: (717) 249-3166
cc: Lindsay Baird, Esquire
David W. Morrison
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JENIFER A. MORRISON : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : No. 99- CIVIL TERM
DAVID W. MORRISON,
Defendant IN CUSTODY
COMPLAINT FOR CUSTODY
1. The plaintiff is Jenifer A. Morrison, residing at 72 Marsh Drive, Carlisle,
Cumberland County, Pennsylvania.
2. The defendant is David W. Morrison, residing at 1283 Crottlestown Road,
Chambersburg, Franklin County, Pennsylvania.
3. Plaintiff seeks custody of the following child:
Name Present Residence Age
Sage S. Morrison 72 Marsh Drive, Carlisle, PA 2
The child was not born out of wedlock.
The child is presently in the custody of mother who resides at 72 Marsh Drive,
Carlisle, Pennsylvania 17013.
During the past two years, the child has resided with the following persons and
at the following addresses:
Person Address Dates
Jenifer A. Morrison 72 Marsh Drive, Carlisle, PA 12/31/98-Present
Jenifer and David Morrison 3710 Boyer Road, Chambersburg, PA 5/7/97-12/31/98
The mother of the child is Jenifer A. Morrison, currently residing at 72 Marsh
Drive, Carlisle, PA.
She is married.
The father of the child is David W. Morrison, currently residing at 1283
Crottlestown Road, Chambersburg, PA.
He is married.
4. The relationship of plaintiff to the child is that of mother. The plaintiff
currently resides with the following persons:
Name Relationship
Sage S. Morrison Son
Robert McLaughlin Son's maternal Grandfather
Carol McLaughlin Son's maternal Grandmother
S. The relationship of defendant to the child is that of father. The defendant
currently resides with the following persons:
Name Relationship
William Morrison Son's (Sage) paternal Grandfather
Vonda Morrison Son's paternal Grandmother
6. 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 another court.
Plaintiff has no information of a custody proceeding concerning the child
pending in a court of this Commonwealth.
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.
7. The best interest and permanent welfare of the child will be served by
granting the relief requested because:
a) Plaintiff can provide the child with a home with adequate moral, emotional
and physical surroundings as required to meet the child's needs;
b) Plaintiff is willing to accept custody of the child;
c) Plaintiff continues to exercise parental duties and enjoys the love and
affection of the child.
8. Each parent whose parental rights to the child have not been terminated and
the person who has physical custody of the child 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 child will be given notice of the pendency of this action
and the right to intervene:
Name Address Basis of Claim
NONE
Wherefore, plaintiff requests the court to grant custody of the child.
?f1..,n/ten. (! ?S.', i !Cl(kwy
Li say Dare B?#d, Esquire
South Hanover
Carlisle, PA 17013
Attorney for Plaintiff
I verify that to best of my knowledge and belief, the statements made in this
Complaint 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.
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JENIFER A. MORRISON : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : No. 99.3763 CIVIL TERM
DAVID W. MORRISON,
Defendant IN CUSTODY
ORDER OF COURT
AND NOW, this A- day of V-0A , 1999, upon consideration of the attached
custody stipulation with respect to the parties' child, Sage S. Morrison, born May 7, 1997, the
terms of the stipulation are entered as an order of court.
Lindsay Dare Baird, Esq.
37 South Hanover Street
Carlisle, PA 17013
Attorney for Plaintiff
m ?10/ rpIGq,
David W. Morrison
99 ACT
4YLVa
JENIFER A. MORRISON : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : No. 99. 3763 CIVIL TERM
DAVID W. MORRISON,
Defendant IN CUSTODY
STIPULATION FOR CUSTODY
STIPULATION made this /3 y/,day of October, 1999, between Jenifer A.
Morrison, hereinafter referred to as Mother, and David W. Morrison,
hereinafter referred to as Father.
WHEREAS, the above-named Mother and Father had born to them the following
child on the following date:
NAME BIRTHRATE
Sage S. Morrison May 7, 1997
AND WHEREAS, the above-named Mother and Father desire to enter into a
Stipulation as to the custody of the above-said child:
NOW, THEREFORE, in order to effectuate the above purpose, the above-named
Mother and Father hereby stipulate that:
1. The Mother and Father shall have shared legal custody of the child.
2. The Mother shall have primary physical custody of the child.
3. The Father shall have periods of partial custody as follows:
a. Every other weekend at paternal grandparent's home.
b. Any other times the parties may agree upon.
9. The Father shall not consume alcohol during his periods of partial
custody.
TO THIS PURPOSE, the parties hereto intend to be legally bound by the terms of
this Stipulation and desire to have the Stipulation entered as an Order of
Court.
WITNESS:
'J?ifeM}1- Mori on, Mother
n say Dare ,B /ir?d Esquire David W. Morrison, Father
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OCT 2 0 1999
JENIFER A. MORRISON.
Plaintiff
v
DAVID W. MORRISON,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99-3763 CIVIL
IN CUSTODY
COURTORDER
AND NOW, this ZP day of October, 1999, the Conciliator being advised that the parties have
reached an agreement, the Conciliator relinquishes jurisdiction.
BY THE COURT,
Hubert X. Gilroy, E!
Custody Conciliator
BLED-0fICE
O= Tt-- ra?rF'^.`;pTARY
99 OCT 21 A!1 9: 58
C;CUNTY
PENN1 (LVrr6\