HomeMy WebLinkAbout99-06299
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Donald G. Clark, Jr. and
Kathleen Clark,
Plaintiffs
VS.
Robbi Lynn Latchford and
John Elvin Mollson,
Defendants
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99-W &IVIL TERM
CUSTODY
9RDRR OF CO[1RT
AND NOW, this 1yo^day of
? upon consideration of the within Petition and
upon Agreement of the parties attached to the within Petition as Exhibit "A", it is ordered and decreed that
legal custody and primary custody of Zachary Ryan Clark be granted to Donald G. Clark, Jr. and
Kathleen Clark, with partial custody to Bobbi Lynn Latchford, as more specifically set forth in the
Agreement of the parties.
t
FILED-OFFICE
OF TriE FROMPOTARY
99 OCT 19 AM 8: 48
CUM LA,gD COUNTY
F'Ef?WSYLVANIA
Donald G. Clark, Jr, and
Kathleen Clark,
Plaintiffs
VS.
Bobbi Lynn Latchford and
John Elvin Mollson,
Defendants
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99-WR CIVIL TERM
CUSTODY
AND NOW, conies Donald G. Clark, Jr. and Kathleen Clark, Plaintiff herein, by and through
his attorneys, Frey & Tiley, and makes the following statement:
Plaintiffs arc Donald G. Clark, Jr. and Kathleen Clark, husband and wife, adult
individuals, of 513 South Pitt Street in the Borough of Carlisle, Cumberland County, Pennsylvania.
2, Defendant, Bobbi Lynn Latchford, is an adult individual residing at 2459 North 5th Street,
Harrisburg, Dauphin County, Pennsylvania.
3. Defendants, John Elvin Molison, is an adult individual residing at 107 Ironstone Road,
New Cumberland, Pennsylvania.
4. Defendants are the natural parents of Zachary Ryan Clark, born May 18, 1985, currently
residing with Plaintiffs at 513 South Pitt Street in the Borough of Carlisle, Cumberland County,
Pennsylvania.
5. Plaintiffs and Defendants have entered into an agreement concerning the custody and
visitation of the aforesaid child and have agreed that said agreement may be entered as an Order of Court.
Said agreement is attached hereto and incorporated herein as Exhibit "A".
6. Plaintiffs now desire to have this agreement entered as an Order of Court as it is believed
that the terms of the agreement will best serve the interests of the aforesaid child.
WHEREFORE, Plaintiffs respectfully request that the Court grant legal custody and primary
physical custody to Plaintiffs with partial custody to Defendant as agreed to by the parties in Exhibit "A".
Respectfully submitted,
by:
Frey & Tiley
y
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I verify that the statements made herein are true and cornet and understand that false statements
herein arc made subject to the penalties of 18 Pa. C. S. A. § 4904 relating to unsworn falsification to
authorities.
Dated: 1999 -
Do Mild G. Clark, Jr.
KaIh cn Clark
4'
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TEMPORARY CUSTODY AGREEMENT
ENTERED INTO this 19'?4 day of c?C?'t!E^???'? 1999
BETWEEN, Donald G. Clark, Jr. and Kathleen Clark, husband and wife, of 513
South Pitt Street, Carlisle, Cumberland County, Pennsylvania, hereinafter referred to as "Uncle
and Aunt",
AND Bobbi Lynn Latchford, of 2459 North 5th Street, Harrisburg, Dauphin
County, Pennsylvania, hereinafter referred to as "Mother',
AND John Elvin Molison, of 107 Ironstone Road, New Cumberland,
Cumberland County, Pennsylvania, hereinafter referred to as "Father';
W"FREAS, Mother is the parent of 7aebary Ryan Clark, born May 18, 1995, minnr.
hereinafter referred to as "the child"WHEREAS, Mother asserts that Father is also the parent of the child but Father does-.&W f*
acknowledge or admit to patcmity of the child;
WHEREAS, Father and Mother are not living together and Father has had no contact with
the child;
WHEREAS, Uncle and Aunt have expressed a willingness to care for the child;
WHEREAS, all parties acknowledge that the child is now living with Uncle and Aunt and
has been living with them since October 30, 1998;
WHEREAS, all panics believe that the best interests of the child is served by the present
custodial arrangement;
WHEREAS, all parties believe that it is in the best interests of the child to reach an
agreement as to the relative custody, partial custody, and visitation of their child;
WHEREAS, all panics desire to have said agreement entered as an Order of Court having
jurisdiction over
NOW THEREFORE, in consideration of the mutual covenants, promises, and
agreements as hereinafter set forth, the panics agree as follows;
Uncle and Aunt shall have joint legal custody of the child.
2. Uncle and Aunt shall have primary physical custody of the child.
3. Mother shall have reasonable periods of partial or temporary custody with the child,
as agreed upon by the parties. Father acknowledges that he does-W*dcsire and does4h* seek
partial or temporary custody or visitation. exe %C)
4. The panics agree that the exchange of the child in all cases shall occurat the home
of Uncle and Aunt, 513 South Pitt Street, Carlisle, Pennsylvania.
5. The parties agree that they will work to the best interests of child.
MINT "A•
6. The parties agree that they will each notify the other immediately in cases of medical
emergencies that occur while the child is in the custody of her or him.
7. Any modification or waiver of tiny of the provisions of this Agreement shall be
effective only if made in writing executed with the same formality as this Agreement.
8. Neither party shall do anything which may estrange the child from the other or
injure the opinion of the child as to the other, or which may hamper the free and natural
development of the child's love or affection for the other.
9. The parties each agree that in making this Agreement, there has been no fraud,
concealment, overreaching, coercion, or other unfair dealing on the part of the other.
10. It is understood by the parties that this Agreement may be submitted for
incorporation into an Order of Court and may be modified by the Court of Common Pleas of
Cumberland County or any other Court having propcrjurisdiction based on the laws in effect in the
jurisdiction.
INTENDING to be legally bound, witness our hand and seal the day and year first above
written.
tea= 1 (SEAL)
obi Lynn Latchford
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OCT'I 1 5 19!1
I
DONALD G. CLARK, JR AND KATHY R. CLARK : IN TIIE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
JOHN E. MOLISON AND BOBBI L. LATCHFORD
DEFENDANT 99-6299 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this 23rd day of August , 2000, upon consideration of the attached Complaint,
it is hereby directed that the parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator,
at 39 West Main Street, 111echaniesburg. PA 17055 on the 191h day of September , 2000, at 3:00 p.m.
for a Prc-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 may also be present at the confcrcnce. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
FOR THE COURT,
By: ls/ Dawn S. Sunday. Esq?
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
Carlisle. Pennsylvania 17013
Telephone (717) 249-3166
DONALD C. CLARK, JR. and : IN THE COURT OF COMMON PLEAS OF
KATHY R. CLARK, : CUMBERLAND COUNTY, PENNSYLVANIA
Petitioners,
NO.99-6299 CIVIL TERM
V.
JOHN E. MOI.ISON and
BOBBI L. LATCHFORD, : IN CUSTODY
Respondents.
ORDER OF COURT
AND NOW this day of 2000, upon consideration of the attached
Petition Requesting Leave of Court, it is hereby ordered that a hearing on this matter shall be held on
2000, in Courtroom # . at o'clock in the Cumberland
County Courthouse, Carlisle, Pennsylvania.
By the Court,
J.
`r
DONALD G. CLARK, JR. end : IN THE COURT OF COMMON PLEAS OF
KATHY R. CLARK, : CUMBERLAND COUNTY, PENNSYLVANIA
Petitioners,
NO. 99-6299 CIVIL TERM
V.
JOAN E. NIOLISON and
BOBBI L. LATCHFORD, : IN CUSTODY
Respondents.
ORDER OFCOURT
AND NOW, this day of 2000, on consideration of the attached
petition, it is hereby directed that the parties and their respective counsel appear before Hubert X. Gilroy,
Esquire, the conciliator, on the 4th Floor, Cumberland County Courthouse, on the _ day of
2000, at . M. for a PmHearing 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. Failure to appear at this
conference may provide grounds for entry of a temporary or permanent order.
By the Court,
By:
Custody Conciliator
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
1-800-990-9108
AMERICANS WITH DISABILITIES
ACT OF 1990
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.
,-,
DONALD G. CLARK, JR. and
KATHY R. CLARK,
Petitioners,
V.
JOHN E. MOLISON and
BOBBI L. LATCHFORD,
Respondents.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-6299 CIVIL TERM
: IN CUSTODY
PETITION FOR LEAVE OF COURT
AND NOW, come the Petitioners, Donald G. Clark, Jr., and Kathy R. Clark, by and
through their attorneys, 1RWIN, McKNIGHT & HUGHES, Esquires, and files this Petition for
Leave of Court making the following statement:
1. The Petitioners are Donald G. Clark, Jr. and Kathy R. Clark.
2. Donald G. Clark, Jr., is an adult individual residing at 5 Tortola Lane, Ocean
Pines, Maryland 21811.
3. The Petitioner, Kathy R. Clark, is an adult individual residing at 513 South Pitt
Street, Carlisle, Cumberland County, Pennsylvania 17013.
4. The Respondents, John E. Molison and Bobbi L. Latchford, are the natural
parents of Zachary Clark, a minor child born on May 18, 1995.
5. The Respondent, John E. Molison, an adult individual, is residing at The Best
Western, Carlisle, Pennsylvania.
6. The Respondent, Bobbi L. Latchford, is currently residing at the Cumberland
County Prison, Carlisle, Pennsylvania.
7. On or about October 1998, the Petitioners obtained custody of the minor child
with the consent of the natural parents who, at the time custody was obtained by the Petitioners,
were married.
8. At the time of receipt of custody of the minor child, the Respondents entered into
an agreement on or about January 5, 1999, and then subsequently entered into a second
agreement on or about October 18, 1999. Attached as Exhibit "A" arc true and correct copies of
said agreements.
9. Since that time, the Petitioners have continued to maintain custody of the minor
child with very sporadic visits by the Respondents.
10. Within the last eight (8) months, the Respondents have visited the minor child as
follows:
a. December 25, 1999, a visit took place for one-half (1/2) hour by
the Respondents;
b. The Respondents called the minor child on his birthday
(Mayl8) this past birthday (the year 2000); and
c. Since June, 2000 the Respondents have visited with the minor
child approximately four (4) times.
11. The Petitioners have always entertained requests from the Respondents to visit the
minor child, however, these requests have been scarce since the Petitioners have obtained
custody of the minor child.
12. On or about the beginning of May, 2000, the Petitioner, Donald G. Clark, Jr.,
moved down to his current address in Maryland to obtain employment which would better
support his family.
13. The Petitioners have two (2) minor children of their own who have also resided
with the minor child since the date the Petitioners received custody.
14. Since the beginning of May, the minor child has remained residing with the
Petitioner, Kathy R. Clark, at her current residence.
15. The Petitioners have resided apart since the beginning of May to be sure that the
employment received by Donald G. Clark, Jr., would be sufficient and reliable to better support
the family.
16. At this point, the Petitioners believe and therefore aver that it would be in the
minor child's best interest to move with them to Maryland where the Petitioner, Donald G.
Clark, Jr., is currently residing.
WHEREFORE, the Petitioners, Donald G. Clark, Jr., and Kathy R. Clark, respectfully
request that they be granted Leave of Court to move with the minor child, Zachary Clark, to
Maryland.
Respectfully submitted,
IRWIN, McKNIGHT & HUGHES
13y:
Rebecca R. Hughes, Esqul e
60 West Pomfret Street
Carlisle, PA 17013
(717) 249-2353
Supreme Court I.D. No: 67212
Attorney for the Petitioners,
Donald G. Clark, Jr., and
Kathy R. Clark
Datcd: August 2000
EXHIBIT "A
TEMPORARY CUSTODY AGREEMENT
ENTERED INTO this T t{- day of SA ?? 7 1999
BETWEEN, Donald G. Clark, Jr, and Kathleen Clark, husband and wife, of 513
Auntouch"Pitt Street, Carlisle, Cumberland County, Pennsylvania, hereinafter referred to as "Uncle and
,
AND Bobbi Lynn Latchford, of 2459 North 5th Street, Harrisburg, Dauphin
County, Pennsylvania, hereinafter referred to as "Mother,
AND Donald G. Clark, Sr. and Frances L. Clark, husband and wife, of 63
West North Street, Carlisle, Cumberland County, Pennsylvania, hereinafter referred to as
"Grandparents";
WHEREAS, John Elvin Molison and Mother are the parents of Zachary Ryan Clark,
born May 18, 1995, minor, hereinafter referred to as "the child"WHEREAS, Father and Mother are no longer living together and Father has had no
contact with the child and his present whereabouts are unknown;
WHEREAS, Uncle and Aunt have expressed a willingness to care for the child while
Mother completes her education and obtains employment;
WHEREAS, all parties acknowledge that the child is now living with Uncle and Aunt and
has been living with them since October 30, 1998;
WHEREAS, all parties believe that the best interests of the child is served by the present
custodial arrangement;
WHEREAS, all parties believe that it is in the best interests of their child to reach an
agreement as to the relative custody, partial custody, and visitation of their child;
WHEREAS, all parties desire to have said agreement entered as an Order of Court having
jurisdiction over
NOW THEREFORE, in consideration of the mutual covenants, promises, and
agreements as hereinafter set forth, the parties agree as follows:
Mother and Uncle and Aunt shall havejoint legal custody of the child.
Uncle and Aunt shall have primary physical custody of the child.
3. Mother shall have reasonable periods of partial or temporary custody with the child,
as agreed upon by the parties,
4. The parties agree that the exchange of the child in all cases shall occur at the home
of Uncle and Aunt, 513 South Pitt Street, Carlisle, Pennsylvania.
The parties agree that they will work to the best interests of child.
6. The parties agree drat they will each notify the other immediately in cases of medical
emergencies that occur while the child is in the custody of her or him.
7. Any modification or waiver of any of the provisions of this Agreement shall be
effective only if made in writing executed with the same formality as this Agreement.
8. Neither party shall do anything which may estrange the child from the other or
injure the opinion of the child as to the other, or which may hamper the free and natural
development of the child's love or affection for the other.
9. The parties each agree that in making this Agreement, there has been no fraud,
concealment, overreaching, coercion, or other unfair dealing on the part of the other.
10. It is understood by the parties that this Agreement may be submitted for
incorporation into an Order of Court and may be modified by the Court of Common Pleas of
Cumberland County or any other Court having proper jurisdiction based on the laws in effect in the
jurisdiction.
11. The Grandparents join in this agreement to signify their agreement with the
custodial arrangement and to confirm their willingness to assist in the making of decisions required
by those having legal custody of the child.
12. It is agreed by the parties hereto that this agreement is temporary in nature and
should have a duration of one (1) year. The Agreement is designed to afford a one-year
opportunity to Mother to develop her accadenmic and financial resources so that she may better
provide for the needs of the child an the future. Being a temporary agreement, the panics agree that
legal and physical custody should be returned to Mother when it is agreed by all parties that she is
able to adequately care for the child. If the parties fail to reach agreement for the return of legal and
physical custody, any party hereto may file a petition seeking legal and/or physical custody.
written. to be legally bound, witness our hand and seal the day and year first above
(SEAL)
*Bobbi chford
Donald G. Clark, Jr. and
Kathleen Clark,
Plaintiffs
VS.
Bobbi Lynn Latchford and
John Elvin Mollson,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
NO. 99-(O CIVIL CIVIL TERM
: CUSTODY
ORDER Or CO RT
AND NOW, this 1O day of ?ollV;'1? upon consideration of the within Petition and
upon Agreement of the parties attached to the within Petition as Exhibit "A", it is ordered and decreed that
legal custody and primary custody of Zachary Ryan Clark be granted to Donald G. Clark, Jr. and
Kathleen Clark, with partial custody to Bobbi Lynn Latchford, as more specifically set forth in the
Agreement of the parties.
TRUE^??? s^?1? pr?nR?
In Test r..-
and du ..c. t y head
t Cori'. a, Via.
This ....1..9.. d y o. ......, 19..2.
Prothonotary
Donald G. Clark, Jr. and : IN THE COURT OF COMMON PLEAS OF
Kathleen Clark,
Plaintiffs : CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
Bobbi Lynn Latchford and : NO. 99-CIVIL TERM
John Elvin Molison,
Defendants CUSTODY
ORDE OF ('O RT
AND NOW, this day of , upon consideration of the within Petition and
upon Agreement of the parties attached to the within Petition as Exhibit "A", it is ordered and decreed that
legal custody and primary custody of Zachary Ryan Clark be granted to Donald O. Clark, Jr. and
Kathleen Clark, with partial custody to Bobbi Lynn Latchford, as more specifically set forth in the
Agreement of the parties.
BY THE COURT,
J.
Donald G. Clark, Jr. and : IN THE COURT OF COMMON PLEAS OF
Kathleen Clark,
Plaintiffs : CUMBERLAND COUNTY, PENNSYLVANIA
vs' : CIVIL ACTION - LAW
Bobbi Lynn Latchford and NO. 99- CIVIL TERM _ n
John Elvin Mollson, `-
Defendants : CUSTODY
PETITION AND NOW, comes Donald G. Clark, Jr. and Kathleen Clark, Plaintiff herein, by and th ought
his attorneys, Frey & Tiley, and makes the following statement:
1. Plaintiffs are Donald G. Clark, Jr. and Kathleen Clark, husband and wife, adult
individuals, of 513 South Pitt Street in the Borough of Carlisle, Cumberland County, Pennsylvania.
2. Defendant, Bobbi Lynn Latchford, is an adult individual residing at 2459 North 5th Street,
Harrisburg, Dauphin County, Pennsylvania.
3. Defendants, John Elvin Molison, is an adult individual residing at 107 Ironstone Road,
New Cumberland, Pennsylvania.
4. Defendants are the natural parents of Zachary Ryan Clark, born May 18, 1985, currently
residing with Plaintiffs at 513 South Pitt Street in the Borough of Carlisle, Cumberland County,
Pennsylvania.
5. Plaintiffs and Defendants have entered into an agreement concerning the custody and
visitation of the aforesaid child and have agreed that said agreement may be entered as an Order of Court.
Said agreement is attached hereto and incorporated herein as Exhibit "A".
6. Plaintiffs now desire to have this agreement entered as an Order of Court as it is believed
that the terms of the agreement will best serve the interests of the aforesaid child.
WHEREFORE, Plaintiffs respectfully request that the Court grant legal custody and primary
physical custody to Plaintiffs with partial custody to Defendant as agreed to by the parties in Exhibit "A".
Respectfully submitted,
Frey & Tiley
by:
I verify that the statements made herein are true and correct and understand that false statements
herein are made subject to the penalties of 18 Pa. C. S. A. § 4904 relating to unswom falsification to
authorities.
Dated: 4lcDo? G. C ark, Jr.
4Katen Clark . a
41
'r
F
?d
1':3
TEMPORARY 1RTnnV Allorrnx".,m
ENTERED INTO this /p4 day of C?,f K 1999
BETWEEN, Donald G. Clark, Jr. and Kathleen Clark, husband and wife, "
South Pitt Street, Carlisle, Cumberland County, Pennsylvania, hereinafter referred e, "Uncle
cle of 513
and Aunt",
to as Uncle
AND Bobbi Lynn Latchford, of 2459 North 5th Street, Harrisburg, Dauphin
County, Pennsylvania, hereinafter referred to as "Mother",
AND John Elvin Molison, of 107 Ironstone Road, New Cumberland,
Cumberland County, Pennsylvania, hereinafter referred to as "Father";
WHEREAS, Mnther is the. parent of Zachary Ryan Clark, barn May 18, 1995, minor,
hereinafter referred to as "the child";
WHEREAS, Mother asserts that Father is also the parent of the child but Father does4a,von
acknowledge or admit to paternity of the child;
WHEREAS, Father and Mother are not living together and Father has had no contact with
the child;
WHEREAS, Uncle and Aunt have expressed a willingness to care for the child;
WHEREAS, all parties acknowledge that the child is now living with Uncle and Aunt and
has been living with them since October 30, 1998;
WHEREAS, all parties believe that the best interests of the child is served by the present
custodial arrangement;
WHEREAS, all parties believe that it is in the best interests of the child to reach an
agreement as to the relative custody, partial custody, and visitation of their child;
WHEREAS, all parties desire to have said agreement entered as an Order of Court having
jurisdiction over
NOW THEREFORE, in consideration of the mutual covenants, promises, and
agreements as hereinafter set forth, the parties agree as follows:
1. Uncle and Aunt shall have joint legal custody of the child.
2. Uncle and Aunt shall have primary physical custody of the child.
3. Mother shall have reasonable periods of partial or temporary custody with the child,
as agreed upon by the parties. Father acknowledges that he does net-desire and doesr
partial or temporary custody or visitation. J17. fete ye'?1 o /,ec
4. The parties agree that the exchange of the child in all cue's shall occur at home
of Uncle and Aunt, 513 South Pitt Street, Carlisle, Pennsylvania.
5. The parties agree that they will work to the best interests of child.
MINT $&A.
6. The parties agree that they will each notify the other immediately in cases of medical
emergencies that occur while the child is in the custody of her or him.
7. Any modification or waiver of any of the provisions of this Agreement shall be
effective only if made in writing executed with the same formality as this Agreement.
8. Neither party shall do anything which may estrange the child from the other or
injure the opinion of the child as to the other, or which may hamper the free and natural
development of the child's love or affection for the other.
9. The parties each agree that in making this Agreement, there has been no fraud,
concealment, overreaching, coercion, or other unfair dealing on the part of the other.
10. It is understood by the parties that this Agreement may be submitted for
incorporation into an Order of Court and may be modified by the Court of Common Pleas of
Cumberland County or any other Court having proper jurisdiction based on the laws in effect in the
jurisdiction.
written. to be legally bound, witness our hand and seal the day and year first above
(SEAL)
o bi Lynn Latchford
VERIFICATION
I have read the statements made in the foregoing document and they are true and correct
to the best of my knowledge, information and belief. I understand that false statements herein
made are subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unswom falsification
to authorities.
TH CLARK
Date: AugustJ6-J2000
VERIFICATION
The foregoing Petition for Leave of Court on behalf of the Petitioners, Donald G. Clark,
Jr., and Kathy R. Clark, is based upon information which has been gathered by counsel for the
Petitioners in the preparation of this Petition. The statements made in this Petition are true and
correct to the best of the counsel's knowledge, information and belief. The Petitioncr, Donald G.
Clark, Jr., is presently out of the jurisdiction of the court and his verification cannot be obtained
within the time allowed for filing the Petition. The undersigned is therefore verifying on behalf
of the Petitioner, Donald G. Clark, Jr., according to 42 Pa.C.S.A. § 1024(c)(2). The undersigned
understands that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section
4904, relating to unswom falsification to authorities.
Rebecca R. Hughes,
Date: August-/ 1Z2000
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DONALD G. CLARK, JR. and
KATHY R. CLARK,
Petitioners,
V.
JOHN E. MOLISON and
BOBBI L. LATCHFORD,
Respondents.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-6299 CIVIL TERM
IN CUSTODY
PRAECIPE TO WITHDRAW PETITION FOR LEAVE OF COURT
To: Prothonotary
Please withdraw the Petition for Leave of Court in the above-captioned matter filed on
August 15, 2000.
IRWIN, McKNIGHT & HUGHES
Rdbecca R. ffugNc , E. ui
60 West Pomfret S •t
Carlisle, PA 17013
(717) 249-2353
Supreme Court I.D. 67212
Attorney for Petitioners,
Donald G. Clark, Jr. and
Kathy R. Clark
Dated: October 9, 2000
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OCT ] 9 200
DONALD C. CLARK, JR. and KATHY R. : IN THE COURT OF COMMON PLEAS OF
CLARK, Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
va. : NO. 99-6299 CIVIL TERM
CIVIL ACTION - LAW
JOHN E. MOLISON and BOBBI L.
LATCHFORD, Defendant IN CUSTODY
ORDER OF COURT
MID NOW, this 12th day of October, 2000, the Conciliator, being
advised by Plaintiffs' counsel that Plaintiffs' Petition for Leave of
Court is being withdrawn, hereby relinquishes jurisdiction in this case.
The Custody Conciliation Conference scheduled for November 91 2000 is
canceled.
FOR THE OOURT,
Dawn S. Sunday, Esquire
Custody Conciliator
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