HomeMy WebLinkAbout99-044081
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MICHAEL F. DAU and CYNTHIA G.
Petitioners
V.
MORGAN MATTER,
: IN THE COURT OF COMMON
: PLEAS OF CUMBERLAND COUNTY
: PENNSYLVANIA
No. 4 9 - LJ 4u d' &,w.j Tw--
Respondent : IN CUSTODY
AND NOW COMES, Petitioner, Michael F. Dau and Cynthia G. Dau, through
their Attorney, The Law Office of Darrell C. Dethlefs and aver in support of thew Petition
as follows:
1. Petitioners, Michael F. Dau and Cynthia G. Dsu, are husband and wife
currently residing at 10 Plainview Road, Camp Hill, Cumberland County,
Pennsylvania.
2. Respondent, Morgan Matter, is an adult individual currently residing in
Steelton, Pennsylvania.
Respondent, Morgan matter, is the natural mother of Tonia Marie Owens
bom July 23, 1992, hereinafter "the child".
4. Petitioner's are the Uncle and Aunt of Respondent, Morgan Matter.
5. The natural father of the child, Andre Owens, lives in the State of
Maryland. His exact whereabouts is unknown.
6. The natural father, Andre Owens, has not had any contact whatsoever with
said child for over three (3) years.
7. Both Petitioners and Respondent, in an effort to insure that the best
interests of the child are met, have agreed upon the terms and conditions of
a Stipulation Agreement as to the custody and visitation. the original of
which is attached hereto as Exhibit "A".
WHEREFORE, Petitioner respectfully requests to have the aforementioned
agreement as to the custody and visitation of the child incorporated into an order
enforceable by the court.
Respectfully Submitt
Date: '? 12 I q 9 By:
Michael I Pykosh
Attorney I.D. 58 51
3805 Market Street
Camp Hill, Pa 17011
(717)975-9446
MICHAEL F. DAU and CYNTHIA G.
Petitioners
V.
: IN THE COURT OF COMMON
: PLEAS OF CUMBERLAND COUNTY
: PENNSYLVANIA
No. 99- NYOg `(?? Q T?.
MORGAN MATTER,
Respondent
: IN CUSTODY
STIPULATION AREEMENT A TO CUSTODY AND VISITATION
ON THIS J,?, day of JLLtLA , 1999, Michael F. Dau and Cynthia
G. Dau of 10 Plainview Road, Cumberland County, Pennsylvania, hereinafter "Petitioner"
and Morgan Matter of Harrisburg, Pennsylvania, hereinafter "Mother" hereby agree to the
following terns and conditions of the custody and visitation of Tonia Marie Owens born
July 23, 1992, hereinafter "the child". Petitioner and Respondent recite and declare as
follows:
1. Petitioner and respondent, mother, agree that Petitioners shall maintain sole
legal custody of said child.
2. Petitioner and respondent, mother, agree that Petitioner shall maintain
primary physical custody of said child.
3. Petitioner and respondent, mother, agree that mother shall have rights of
visitation as mutually agreed upon by the parties herein.
4. Petitioner and respondent, mother, agree that the terms and conditions of
the agreement are in the best interest of the child.
5. Petitioner and respondent, mother, have both had the opportunity to
consult an attorney prior to executing this agreement.
6. Both parties acknowledge that Michael J. Pykosh of the Law Office of
Darrell C. Dethlefs is representing Petitioners and has not consulted or provided any legal
representation to respondent, mother.
7. Petitioner and respondent, mother, shall hereinafter execute all instruments
necessary to carry out the terms of this agreement.
8. Petitioner and respondent, mother, agree to have this agreement
incorporated into an order enforceable by the court.
WHEREFORE, this agreement shall be binding on the parties and their respective
heirs, executors, administrators, and assigns.
iL Petitione (s)
114 Date:?/i2I ( I? C' Date:-z- /1. / I
Mi hael F. Dau
Witness: I p
e ?I Z??J9 t., Date ?/ q l
Cyn 'a G. Dau `
Witn s:,/? Respondent
Date: Date; H
Morg Matter J
MICHAEL F. DAU and CYNTHIA G. : IN THE COURT OF COMMON
Petitioners : PLEAS OF CUMBERLAND COUNTY
: PENNSYLVANIA
V.
No.
MORGAN MATTER,
Respondent IN CUSTODY
I hereby verify that the statements of fact made in the foregoing PETITION, are
true and correct to the best of my knowledge, information and belief. I understand that
any false statements therein are subject to the criminal penalties contained in 18 Pa C. S.
Section 4904, relating to unsworn fasification to authorities.
Date:
Date: ?1 ?? 9
COMMONWEALTH OF PENNSYLVANIA:
SS:
COUNTY OF
On this, the Z day o 1999, before me, the undersigned
officer personally appeared, Petition s), i hael F. Dan and Cynthia G. Dan, known
to me (or satisfactorily proven) to be the person(s) whose name(s) is/are subscribed to the
within instrument and acknowledged that he/she executed the same for the purposes
herein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
1 , =TWp.,Cumber1 Sperryy Lblic
? '. lampden unty
r'rmm2001
"Ar OAssocialloa of Notaries
otary Pu Ic
My Commission Expires: 0 2(o'SIQ(
COMMONWEALTH OF PENNSYLVANIA:
SS:
COUNTY OF 11 0.d
On this, thel Z ay of 1999, before me, the undersigned
officer personally appeared, Respond t, o an Matter, known to me (or
satisfactorily proven) to be the person(s) whose name(s) is/are subscribed to the within
instrument and acknowledged that he/she executed the same for the purposes herein
contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
Sherr Notarial Seal
y L. Deckman, Notary Public
Hampdon Twp., Cumberland County
My Commission Expires Feb. 5, 2001
My Commission Expires: 02 t6 lD
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