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HomeMy WebLinkAbout03-3614 TODD R. ROLAND, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. oj.3 fpl~ CIVIL TERM ELIZABETH C. ROLAND, Defendant IN CUSTODY COMPLAINT FOR CUSTODY L Plaintiff is Todd R. Roland, who currently resides at 245 Pine Grove Road, Gardners, Cumberland County, Pennsylvania. 1'7 2. Defendant is Elizabeth C. Roland, who currently resides on Main Street, Alexandria, Huntingdon County, Pennsylvania; it is believed she is moving to Philadelphia, Pa, on or about August 1,2003. 3. Plaintiff seeks primary custody of the following children: NAME DOB ADDRESS Zachary Todd Roland 6/5/95 Tiffany Marie Roland 11116/92 during the past several months, custody has been shared between mother's residence in Huntingdon County and father's residence in Cumberland County, Pa. The children were born in wedlock. Father and mother currently share custody of the children. During the past five years, the children have resided with the following persons and at the following addresses: NAME ADDRESSES DATES Todd Roland Elizabeth Roland Petersburg, Pa. 1/97 to 10/01 Todd Roland Elizabeth Roland Betty Nelson Court Carlisle, Pa. 17013 10/01 to 11/02 In November 2002, the couple separated and have had shared custody. The addresses of each party are listed below: Elizabeth Roland Betty Nelson Court Carlisle, Pa. 17013 11/02 to 1/02 Todd Roland 62 Marilynn Drive Carlisle, Pa. 17013 11/02 to 3/02 Elizabeth Roland MainSt. Alexandria, Pa. 1/03 to present Todd Roland Lorie Yost 245 Pine Grove Rd. Gardners, Pa. 17324 4/3 to present The mother of the children is: Elizabeth C. Roland, currently residing at: Alexandria, Huntingdon County, Pennsylvania; it is believed she is moving to Philadelphia, Pennsylvania on or about August 1,2003. She is married to Todd Roland, however a divorce complaint has been filed in Allegheny County, Pennsylvania. The father of the children is: Todd R Roland, currently residing at: 245 Pine Grove Road, Gardners, Cumberland County, Pennsylvania. He is married to Elizabeth C. Roland, however, a divorce complaint has been filed in Allegheny County, Pennsylvania. 4. The relationship of plaintiff to the children is that of FATHER. The plaintiff currently resides with his girlfriend, Lorie Yost. 5. The relationship of defendant to the children is that of MOTHER. The persons that the defendant currently resides with are: unknown. 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Plaintiff does not know of a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 7. The best interest and permanent welfare of the children will be served by granting the relief requested because; Mother was recently evicted from her Huntingdon County residence and is currentlv planning on movin!( to Philadelphia.. Pa.: she has a history of moving frequentlv and has not provided adequate housin!(, medical care, clothing, or food for the children: Father believes he can provide a much more stable home and can provide a better living environment for the children: he currentlv has a stable job and home: therefore, he believes it would be in the best interest of the children to reside primarily with him. 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. WHEREFORE, Plaintiff requests the court to grant Todd Roland primary custody of the children. Date; '1- ~9-D3 Respectfully submitted, GQ9 e Adams, Esquire 1. . No. 79465 6 outh Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ../ 0 ~ 0 ~ c. ..~.) -n ~ , '--\ -ocr.' ; -on fTirr' , , f;:'- Z:)'" N rn &I~ .'~) u:> I =< '~- - ~ ~1 k,'-- -c " . -n ';<>;,- ::~ ~,'~~ 0 ';bJ, c:? .:'-~,cn :;>':2. ,.' '-. ::::> <c_.:_, ::;:: :< VERIFICATION I verifY that 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. g4904 relating to unsworn falsification to authorities. Date: '1 } ~ ~ ~ 3 , --- ~ ~(\ ~ ~ - ....... .f- ..... -..... - c> C --f- 1.-, -f. (,\ }.. ~ -.(1 o C -:;,;: -a2~ rrt,:- ~t~ (f) -' r~" ~;:; 1- 5tt c -j> =.i "' Q " ;:..~ r',", .....() "i, ., ;. ~.) _.-(, ~, ~ C'':; ~;m -, :lJ -< ::> ,t:- TODD R. ROLAND PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 03-3614 CIVIL ACTION LAW ELIZABETH C. ROLAND DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, August 05, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. at 4th Floor, Cumberland Couuty Courthouse, Carlisle on Thursday, September 04, 2003 , the conciliator, at 8:30 AM for a Pre-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 conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearinl(. FOR THE COURT, By; Isl Hubert X, Gilroy, Esq. Custody Conciliator v The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of I 990. For infonnation 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 TI-IIS PAPER TO YOUR ATIORNEY AT ONCE. IF YOU DO NOT HA VB AN ATIORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIlE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~~~~~-4 [0.5$ .& 2? ~J/ ~U; W'?j ~/?? ~ 7- ~4 ~ -f'?;J 87;5,$ V1N':!l\~,'\SNi~3d ..... .'"" :"~:,-.<"V:::) ,... ,_, I' " ,'"11i en ~'l :~, :.,\.1 '.-- 01111 1.,1",' ).,t}ilC<.- ' jO II TODD R. ROLAND, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 0 :, - ~\.o \ V\ CIVIL TERM ELIZABETH C. ROLAND, Defendant : IN CUSTODY AFFIDAVIT OF SERVICJ1~ AND NOW, this August 15,2003 I, Jane Adams, Esquire, hereby certify that on or about August 13, 2003, a certified true copy of the CUSTODY ORDER setting~ hearing date and CUSTODY COMPLAINT were served, via certified mail, return receipt req~sted, restricted delivery, addressed to: Elizabeth Roland 1534 Ben Franklin Highway Douglasville, Pa. 19518 DEFENDANT Respectfully Submitted: Adams, EsqUIre LD. o. 79465 outh Pitt Street Carlisle, Pa. 17013 i (717) 245-8508 1 ATTORNEY FORPLAINTNl I I o [.: iB:~: ~~;. <""'/: S5'~ r-'" 5.C:;;;.-( >'~. J, :i..~':- , - C.L~ :,;? c:, Cv b" C:= V) D " ----I - "::;;~ C)::' (j;~~ Ic;-3Ll ~--F~~~l}- ~p I~-l~ t;c:O ~ 0() d-, . Complete ttems1,~, an411., Also complete , .ttem4Sff, Restricted,D..llV.~ is desired. . Prini~dur name ary;l'addroSs on the reverse so that we can rebJrn the card to you. . A~h this card to the back of the mail piece, or on the front if space permits. 1. Article Addressed to: 2. Article Number (Transfer from service label) DC ~nrm 3811 , March 2001 x < ht::::--. D. \s delivEll'Y address differerrt't;~m item 17 If YES, enter delivery address below: 3. SaNiee Type ..)ur.Ariifi..n Mail o Registered o Insured Mail o Express Mail o Return Receipt for Merchandise DC,O.D, 4. Restricted Delivery? (Extf';!l Fee) dSf!;S- Domestic Return Receipt DYes 10259S.01.M-1424 UNITED STATES POSTAL SERVICE III/II First-Class Mail Postage & Fees Paid USPS Permit No. G-10 . Sender: Please print your name, address, and ZIP+4 in this box. '? JANE ADAMS ATTORNEY AT LAW 36 S. PITT STREET CARLISLE, PA 17013 i (5 1...111...1111/.,../11/111/'//'.,/./1/1././././.1,.1./../.././ AU~ ZM3 TODD R. ROLAND, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. ; NO. 03 - 3614 CIVIL TERM ELIZABETH C. ROLAND, Defendant IN CUSTODY ORDER OF COURT ~ AND NOW, this r.... day of August, 2003, upon consideration of the attached Petition for Emergency Relief, it is hereby Ordered as follows; %0 l'~tition8r, Todd R. RcACu.J, i, gldllU::U iuuue::u!ale:: le::lllpUldlY ':;.l'Stody Qft~" 1;}1inor ehihlr~n, Zl1.chary Todd Roland, ana Tiffauy MaLi" Rulana, and the:: dlaJl"u ,1.llU llttJIW the _ Cmliolil AreA G"hvv\ Di,l1ivl pt:uJ!ng me LUSW<!y C.onclllaLiuu uu S'c::ple::rrl'ber 'I, LUU5. A hearing before the Court is set for the ,i 1-11 day of ~ ,2003, at I fI; , () A'M., in Courtroom No. ;;l::: of the Cumberland County Courthouse. Judge cc: Galen Waltz, Esquire Jane Adams, Esquire TODD R. ROLAND, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. ELIZABETH C. ROLAND, DEFENDANT 03-3614 CIVIL TERM AND NOW, this ORDER OF COURT ""*""- day of August, 2003, following a hearing on the petition of Todd R. Roland for emergency relief, IT IS ORDERED that pending further order of court Zachary Roland, born June 5, 1995, and Tiffany Roland, born November 16, 1992, shall attend school in the school district where the mother is living in Pottstown. Jane Adams, Esquire For Todd Roland Galen Waltz, Esquire For Elizabeth Roland .-t6I'.l.J(A d - .~ 'i?,;l.~AJ3 9-- :saa 'VINliI11ASiVN:Jd "I"nr"-' TI" "~' '-~'^In" I'\.L 'J ,-.II.! .......'.' ,r':':'.'~i}~ V SZ:/ 1{.:J 92 :.JIlV UJ ),bV1Civl:, .il :f0 3OIi:IO-'G3~f'=! SEP 0 5 2003 ~ TODD R. ROLAND, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v CIVIL ACTION - LAW ELIZABETH C. ROLAND, Defendant NO.2003-3614 CIVIL IN CUSTODY COURT ORDER AND NOW, this q01 day of September, 2003, upon consideration of the attached Cnstody Conciliation Report, it is ordered and directed as follows: 1. A hearing is scheduled in Courtroom No. 2 of the Cumberland County Courthouse on the tfUl day of i1...<.~ , 2003, at "t,,'5 A .M. At this hearing, the Father, Todd R. Roland, shall be the moving party and shall proceed initially with testimony. Counsel for the parties shall file with the court and opposing counsel a memorandum setting forth the history of custody in this case, the issues currently before the court, each parties position on those issues, a list of witnesses who will be called to testify and a summary of the anticipated testimony of each witness. This memorandum shall be filed at least five days prior to the mentioned hearing date. 2. Pending further order of this court, it is ordered that the Mother, Elizabeth C. Roland, and the Father, Todd R. Roland, shall enjoy shared legal custody of Zachary T. Roland, born June 5, 1995; and Tiffany M. Roland, born November 16, 1992. 3. Mother shall enjoy primary physical custody of the minor children during the school year so the children may continue to attend school in Pottstown. 4. Father shall enjoy periods of temporary physical custody with the minor children as follows: A. On alternating weekends from Friday at 7:00 p.m. until Sunday at 7:00 p.m. Exchange of custody shall take place at a halfway point between the parties' homes at a location as agreed upon by the parties. B. At such other times as agreed upon by the parties. C. In the event Father's alternating weekend schedule is adjacent to a Monday or Friday holiday from school for the children, Father shall also enjoy custody of the children on those days. For example, if there is a Monday holiday, Father does not need to return the children to Mother until Monday at 7:00 p.m. Ifthere is a Friday holiday, Father will have custody of the minor children on Thursday at 7:00 p.m. J. ) cc: Jane Adams, Esquire Galen R. Waltz, Esquire ~~ 9. /0- b3 c;-" \!\NVii'USNN3d I ","~' ,~, '~~""n" 1\11\; :,e'.. . I:",', ::,~::,i~l v o G :8 Il\' 0 I d3S ~O "tJViC':. ' ;10 :{)I:UQ'G:n~.j TODD R. ROLAND, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW ELIZABETH C. ROLAND, Defendant NO. 2003 -3614 CIVIL IN CUSTODY Prior Judge: Edgar B. Bayley CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITII THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent infonnation pertaining to the children who are the subject of this litigation is as follows: Zachary T. Roland, born June 5, 1995; and Tiffany M. Roland, born November 16, 1992. 2. A Conciliation Conference was held on September 4, 2003, with the following individuals in attendance: The Father, Todd R. Roland, with his counsel, Jane Adams, Esquire; and the Mother, Elizabeth C. Roland, with her counsel, Galen R. Waltz, Esquire. 3. The parties separated in November of last year and had reached an agreement on custody until there was a dispute at the end of the summer with respect to where the children would start school. Mother is living in Pottstown and Father is living in Gardners. Judge Bayley had conducted a short hearing and issued an order on August 28, 2003 specifying that the children should go to school in Pottstown and remain in the primary custody of the Mother during the school year. Father desires to have a more involved hearing in an effort to demonstrate to the court why he believed he should be the primary custodian of the children. Pending that hearing, the parties are willing to work out an arrangement where Father will have temporary custody on alternating weekends. 4. The conciliator recommends the entry of an order in the fonn as attached. 7 a ~ TODD R. ROLAND, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 03 - 3614 CIVIL TERM ELIZABETH C. ROLAND, Defendant : IN CUSTODY MOTION FOR A CONTINUANCE 1. Movant is Jane Adams, Esquire, Attorney for the Plaintiff in the above-captioned matter. 2. Movant's client has indicated he does not wish have the hearing previously scheduled at this time but may be requesting changes in the custody agreement. 3. Movant believes this matter can be resolved through negotiation between the attorneys. 4. Movant has contacted Galen Waltz, Esquire, and he did not indicate any opposition to a general continuance. WHEREFORE, Movant respectfully requests that the (:ustody hearing scheduled for Thursday, December 4th, 2003, at 8:45 a.m. be continued generally and the matter may be re- listed for a hearing by the Court by either party by motion or petition requesting same. Date: I :2-- .'3, . c,3 TODD R. ROLAND, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 03 - 3614 CIVIL TERM ELIZABETH C. ROLAND, Defendant : IN CUSTODY CERTIFICATE OF SERVICE I, Jane Adams, Esquire, hereby certifY that a copy of the attached Petition was served upon the following, by forwarding a true and correct copy of same by the following methods: Galen Waltz, Esquire 37 S. Pitt St. Carlisle, Pa. 170 I3 VIA HAND DELIVERY (/ ~ ./ ~ 0 0 (...... ~T1 r::o ~~R ~'q 11; .-") tftjt I 1ft ;:s c.: (..u ,,::: . ;r~ f8 :r ,'::;--} :oj('') c- - Orll ~ -.... .&:- $ -< <. -~~o ., LUU.J (7 TODD R ROLAND, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 03 - 3614 CIVIL TERM ELIZABETH C. ROLAND, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this S'-/--. day of r~ ,2003, upon review of the Motion for a Continuance, the Court orders and directs that the hearing scheduled for Thursday, December 4, 2003, at 8:45 a.m. is continued generally and the matter may be re-listed for a hearing by the Court upon application of either party by motion or petition. Judge cc: l.6'alen Waltz, Esquire -kne Adams, Esquire )l~ fY/~ !d..Od.-~ .. 'f\N'f^-\J,SNN34 }JNfIOJ Ot.l1\I{jg""no 'IS :2 ~ld c; - :r-.lU CO ;"b'1flONUHl':)(j '~:\.l :l0- 3'J!:\::O-O::;lH TODD R. ROLAND, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 03 - 3614 CIVIL TERM ELIZABETH C. ROLAND, Defendant : IN CUSTODY MOTION FOR A CONTINUANCE I. Movant is Jane Adams, Esquire, Attorney for the Plaintiff in the above-captioned matter. 2. Movant's client has indicated he does not wish have the hearing previously scheduled at this time but may be requesting changes in the custody agreement. 3. Movant believes this matter can be resolved through negotiation between the attorneys. 4. Movant has contacted Galen Waltz, Esquire, and he did not indicate any opposition to a general continuance. WHEREFORE, Movant respectfully requests that the custody hearing scheduled for Thursday, December 4th, 2003, at 8:45 a.m. be continued generally and the matter may be re- listed for a hearing by the Court by either party by motion or petition requesting same. Respectfully Submitted: Date: 1:2- - ~~ . c,3 Adams, Esquire . No. 79465 36 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PETITIONER TODD R. ROLAND TODD R. ROLAND, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 03 - 3614 CIVIL TERM ELIZABETH C. ROLAND, Defendant : IN CUSTODY CERTIFICATE OF SERVICE I, Jane Adams, Esquire, hereby certify that a copy of the attached Petition was served upon the following, by forwarding a true and correct copy of same by the following methods: Galen Waltz, Esquire 37 S. Pitt St. Carlisle, Pa. 17013 VIA HAND DELIVERY L e Adams, Esquire r' f '0 0 ("~. -n ''::> ilfg .'tl ,;J..;' ,>"') ~!t; I ..;:~"p.j r'SC: G_, '.:::~~;: ~ . '"'- 19 :3:: r'~ i"J - ~J: co') - On1 ~ ;g .0:- -0 -< 4 J'..:J TODD R. ROLAND, Plaintiff ; IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 03 - 3614 CIVIL TERM ELIZABETH C. ROLAND, Defendant : IN CUSTODY PRAECIPE TO WITHDRAW CUSTODY COMPLAINT TOTHEPROTHONOTA~Y: ~ AND NOW, this 7-1 day of r ~uAJ.' ,2004, please mark the Custody Complaint, which was filed on July !9~, under the above- captioned number, as withdrawn. Respectfully Submitted, ~J;pC? J e Adams, Esquire .D. No. 79465 36 S. Pitt St Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF .. (") ~; ;:,q{-}'"; ......'1'., '''-'' ~... ' ~r~~=: ~"';. :;! CJ1 o r--.o = c::. .c- ." r'1 CO f'" ~ (') 'n ;;j Hi /2 ;8~~ ,';~(~) (!~2~! ("\,,; ~:;i ~ ::::: C5 ----- /0))6 K ?oL.{1Ji::> lIS Euz,4..i?;~ T f{. C- ROLAN 1:> C>l:;e: Nfl It d6? '3 - 3& i<I Lus TODY 5T.IPULATroN Date Effective: June 10th, 2005 Todd R. Roland and Elizabeth C. Roland do so enter into tbe following agreement reganrding tbe custody of Zaebarv T. Roland and Tiffanv M. Roland. Tbe following agreement is agreed upon by botb parties stated above, tbe agreement sball be as follows, 1 Zacbarv Todd Roland sball reside witb bis fatber Todd R. Roland in Carlisle, PA at bis bome effective June 10th, 2005. 2 Tiffauv Marie Roland shall reside witb ber motber Ellzabetb C. Roland at tbelr current location on Pine Forge Road, P A 3 Todd Roland and Elizabeth Roland sball both maintain Joint Custody of both cbildren witb Todd Roland Iutvinl! PhVllical Custody of Zaclutrv Roland and Elizabetb Roland will have Pbvsical Custody of Tiffanv Rol8.m!. 4 Todd Roland and Elizabeth Roland agree to enact this agreement lnmad of tbe current conrt ordered arrangement. 5 Todd Roland and Elizabetb agree tbat if after 1 school year tbat eitber Zacbarv or Tiffanv wisb to cbange living arrangements tbat Todd and Elizabeth agree to to discuss it witb that child an determine tbe best situation for tbe cbild. 6 Todd R. Roland and Elizabetb C. Roland agree to be financially responsible for tbe cbild theybave in tbeir pbysical custody. 7 Holidays and otber special days througb out tbe year will be discussed as sucb event or day comes up as it bas been done in the past. 8 Starting Summer 2006 Todd Roland and Ellzabetb Roland_agree to switch the cbildren every otber week. So that eacb parent will bave both kids one week and tbe other parent will bave both kids the following wed(, and so on_ 9 Todd Roland and Elizabeth Roland agree tbat starting ..:bool year of 05106 tbey will meet every other weekend. So Ellzahetb will get Zacbary and keep Tiffany for tbe weekend, two weeks later Todd will get Tiffany and keep Zachary. Note: Both agree to giving extra weekends to tbe otber parent when needed or wanted. During the sehool year wboever's weekend it may be lfthe cbild tbey" have bas extra days off school then both Todd and Elizabeth agree to meet early so tbat parent ean bave an extended weekend. Todd and Elizabetb agree to meet at Auf nm at "rystown Exit Tru<:k - ~~ Todd R. Rola~ ;L;OI-/ Date: 6 lid As Ellzabethc.Roland~~lrte:~ 10 11 o c :;, -O;;~;'. n"1ri -'7' .--?" t-"Cj ,:_:~ C'<,. r;;;l ~.~:~--, ~(~; " "-:l :<: .-> ~ <- c:: .- \ cJ1 ~ q, .-\ !f,j2 -olQ :DO c:>,:) ::1!-f. () ::0 "-;TOn ..-r '2, ;;;' .1'1 ...... - - \0 TODD R. ROLAND, PLAINTIFF V. ELIZABETH C. ROLAND : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 03-3614 CIVIL TERM ORDER OF COURT ~ AND NOW, this stipulation is made an order of this court :sal day of July, 2005, the attached custody ''C.. .. Ed~. BaYley~ FIlED-OfFICE OF THE PROTHONOTARY 2005 JUL -8 A1110: St. CUt":-.., . : ,,,, 'NTIJ . .,~_"....! .... ,_ '";,-,,.UI i 1 PE1JNSYLV/,NIA ~ "