HomeMy WebLinkAbout04-4176
BRIAN A. GREGORY,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 04~ 4/71.0
CIVIL TERM
DEENA R. GREGORY,
Defendant
IN CUSTODY
COMPLAINT FOR CUSTODY
AND NOW, comes the Plaintiff, Brian A. Gregory, by and
through
his
attorney,
Mark
w,
Allshouse,
Esquire,
and
respectfully avers the following in support of his Custody
Compliant:
1. The Plaintiff is Brian A. Gregory, an adult individual
residing at 2121 Douglas Drive, Carlisle, Cumberland County,
Pennsylvania.
2, The Defendant is Deena R. Gregory, an adult individual
residing at 17679 S.W. Kinnaman Road, Beaverton, Oregon 97007.
3. The Plaintiff seeks custody of the following child:
Olivia D, Gregory, date of birth May 5, 2000.
The child was not born out of wedlock.
4. The child is presently in the custody of the Defendant
who has unilaterally removed the child from the state and is
believed to be on Oregon,
From birth to the present, Olivia D. Gregory has resided
with the Plaintiff and Defendant,
5.
The father of the child is the Plaintiff,
He is
married to Defendant. The mother of the child is the Defendant,
She is married to Plaintiff.
6. The relationship of Plaintiff to the child, Olivia D.
Gregory is that of Natural Father.
7. Plaintiff currently resides with his Father, Edward
Gregory and step-mother, Arlene Gregory.
8. The relationship of Defendant to the child is that of
Natural Mother.
9. Defendant is believed to currently reside with her
sister, Doris Brown.
10, 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.
11. Plaintiff has no information of a custody proceeding
concerning the child pending in a court of this Commonwealth or
any other state.
12, 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.
13. The best interest and permanent welfare of the child
will be served by granting the relief requested because the
child, Olivia D, Gregory, has always resided with and had
regular contact with the Plaintiff. A minimal but regular
visitation schedule should be established for the Defendant,
14, Each parent whose parental rights to the children have
not been terminated and the person who has physical custody of
the children has been named as a party to this action.
15. The child was born and raised in Cumberland County,
Pennsylvania since birth where many of her immediate family
members and friends are located and has had continued contact
with those family members and friends.
Jurisdiction under the
Uniform Child Custody Act is in Cumberland County, Pennsylvania.
The child was removed to Oregon on or about 8/9/04, which is
less than thirty days ago.
16. Plaintiff has been cut off from all contact with the
child since Defendant left the state.
17. Plaintiff requests an expedited scheduling of the
Custody Conference and a directive that the Child be present at
that conference to ensure her presence in the state, her welfare
and to allow contact with Plaintiff
WHEREFORE, the Plaintiff requests Your Honorable Court to
grant him custody of said child, subject to periods of regular
visitation to the Defendant.
Respectfully submitted,
Date: ~. 23?()Jf
-fl/ff ~{!1f~qUire
~~rney I.D. tS~8014
4833 Spring Road
Shermans Dale, PA 17090
(717) 582-4006
BRIAN A. GREGORY,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO.
CIVIL TERM
DEENA R. GREGORY,
Defendant
IN CUSTODY
VERIFICATION
I, Brian A. Gregory, verify that the statements in the
foregoing document are true and correct to the best of my
knowledge,
information and belief under penal ties
of
18
Pa.C.S.A, Section 4904, relating to unsworn falsification to
authorities.
Date:
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BRIAN A. GREGORY
PLAfNTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
V.
04-4176 CIVIL ACTION LAW
DEENA R. GREGORY
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW,
Tuesday, August 31,2004
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Ja,cqueliue M. Veruey, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, September 16,2004 at 9:30 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 entIy of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existin!: Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearinll.
FOR THE COURT.
By: Isl
Jacqueline M, Vern<ry, Esq,
Custody Conciliator
mhc
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 otlice.
All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must
attcnd 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
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
SEP 2 4 2004 ~
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BRIAN A. GREGORY,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: CIVIL ACTION - JLA W
DEENA R. GREGORY,
Defendant
: NO. 2004-4176 CIVIL TERM
: IN CUSTODY
ORDER OF COURT
AND NOW, this 306(daYOf #/~ ,2004, upon
consideration ofthe attached Custody Cohciliation Report, it is ordered and directed as
follows:
1. A Hearing is scheduled in Co~oom No, _2, of the Cumberland
County Court House, on the / /bl: day of ~/A7r. ~~ ,2004, at dJ: OC;
o'clock, 1. M., at which time testimony will be taken. For purposes of this Hearing,
the Father shall be deemed to be the moving party and shall proceed initially with
testimony. Counsel for each party shall file with the Court and opposing counsel a
Memorandum setting forth each party's position on custody, a list of witnesses who will
be expected to testifY at the Hearing and a summary of the anticipated testimony of each
witness. These Memoranda shall be filed at least ten days prior to the Hearing date,
2, Pending further Order of Court or agreement of the parties, the following
shall remain in effect:
3. The Father, Brian A, Gregory, and the Mother, Deena R. Gregory shall
have shared legal custody of Olivia D, Gregory, born May 5, 2000. Each parent shall
have an equal right, to be exercised jointly with the other parent, to make all major non-
emergency decisions affecting the child's general well-being including, but not limited
to, all decisions regarding her health, education and religion.
4. Mother shall have primary physical custody of the child.
child:
5, Father shall have the following periods of partial physical custody of the
A. Thursday, September 23,2004 from 12:00 noon to 8:00 p,m,
B, Friday, September 24, 2004 from 9:00 a,m, to Saturday at 8:00 p,m,
C. Forty-eight hours either immediately preceding the c:ourt hearing in this matter
or forty-eight hours immediately after the court hear:ing in this matter,
depending on Mother's travel plans, If possible, Father is to have more time if
Mother's travel plans can accommodate additional time. Mother shalJ be
responsible for hers and the Child's airfare,
D. Thanksgiving: Father shalJ have physical Custody of the child within four
hours of Mother's flight arrival until four hours before Mother's flight
departure time. It is anticipated that Mother wilJ arrive on Thursday and
remain at least until Sunday. In the event Thanksgiving weekend is too close
in time to the hearing date, Father may select another extended weekend
nn_y '0 S~"'y) ''''''''' of "''''''g'wng pro",,,, h, g'" Mo""" Wrty
days prior notice, Father shalJ be responsible for the Child's airfare for this
visit and part of Mother's airfare as agreed by the Parties.
E. Such other times as the Parties agree,
6. Transportation shall otherwise be shared sUlch that the Parties shalJ meet at
<h, M,Do",",', 'n C~h", loc,,,,, "" R,~, 74. "'"""" ","""" '""" noJ "" ,
Violation of the PF A.
7. Mother shalJ initiate a telephone calJ between the Child and Father at 9:00
p,m. EST every day. This provision is not a violation of tht) PF A,
8, Neither party may drink alcohol immediately before or during custodial
periods to the point of intoxication,
9. N"<h~ _ ,,,,,,, '0 ~ ~y ~YtlUog ~ P=ilt. <h''''_ '" '0', "y
~yJh",g wlti,. m.y """"g, <h, Cltild finrn "'" oW" pore.., ''Ii"", <h, op;";",, of "'"
Cltild ~ to "'" ,""" ""'" 0' '''''''''' "'" m" ~, 00,""" "''''opm~' of <h, Cbtld',
love and respect for the other parent.
10. The Parties may modify this Order by mutual agreement. In the absence
of mutual consent, the terms of this Order shalJ control.
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CC:~k W. AlJshouse, Esquire, counsel for Father
vF. Stephenson Matthes, Esquire, counsel for Mother
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BRIAN A. GREGORY,
Plaintiff
V.
SEP 2 4 lC04 t
: IN THE COUIitT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
DEENA R. GREGORY,
Defendant
: CIVIL ACTION _ LA W
: NO. 2004-4176 CIVIL TERM
: IN CUSTODY
PRIOR JUDGE: None
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDliRE 1915,3-8, "'" ~"'ed "',,"'" C'",iHoro, ~hmi, "'" fuH,wID,
report:
CUSTODY CONCILIATION SUMMARY REPORT
1, The pertinent infonnation concerning the Child who is the subject of this
litigation is as follows:
NAME
Olivia D, Gregory
DATE OF BIRTH
CUIDrnNTL Y IN CUSTODY OF
May 5, 2000
Mother
2, A Conciliation Conference Was held September 23, 2004 with the
f, H,w", g '''''' ';d"", '" """"'"re, 'n" ''''''''', Bri", A, Greg,'Y, wi m hi, ~""'I.
M", W. AHw,,~, "",..re, "'" m, M<><ho" """00 R. Greg,ry, wim h. ~"",I, F.
Stephenson Matthes, Esquire.
3, Father's position on Custody is as follows: Father seeks shared legal
"""'dy "'d primoy phy""" "'''ody. 0,", ,b,,,, A,,,,. 9,2004, Mo""" removed m,
Child from P"""yl,""" "'" mo"" ro OregO" Po""" 'bj,", ro "'" re '0"'"""
..~rtiog m"",,, Child "" =ided ,H ofh. "fe i, "'" C"Ii,j, "",. P,m,,', rnm;Jy"
in Carlisle. He denies the PF A that has been filed against him in Oregon.
4, Mother's Position on custody is as follows: Mother seeks shared legal
Custody and primary physiCal Custody. She asserts that she left Carlisle because Father
lwd , dri""i"" pmbl'm ,"" "" ,h~,w ,,"'''' Iu". M,m" h.. " f""ijy i, C"Ii,le.
but family in Oregon.
5. The "'",'Ii"" '~'mm""" '" oro" i, m, fm", '" '''''''bed ~hed'Ii""
a Hearing and granting the parents shared legal Custody, Mother primary phYsical
custody and Father Partial physical custody, It is expected that the Hearing will require
one day.
9-.l-t/-ol(
Date
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Custody Conciliator
BRIAN A. GREGORY,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
V.
NO. 2004-4176 CIVIL TERM
DEENA R. GREGORY,
Defendant
IN CUSTODY
01U)ER OF COURT
AND NOW, thiS~ day of october, 2004, upon consideration of
plaintiff's Request for Continuance, it is ordered and directed as
follows:
1, The hearing previously scheduled for December 1, 2004, at
9:00 a.m. in Court RoOm #2 of the Cumberland County Courthouse is
continued to the following date and time:
December 6, 2004 in Court Room #2 in the cumberland
County courthouse to begin at 1:30 p.m.
2. All other provisions of the Order of this Court dated
'epc-" 30". 2004. cegacd'ng che above capcion,d maUec ahall cemaio
in full force and effect.
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BRIAN A. GREGORY,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
DEENA R. GREGORY,
DEFENDANT
04-4176 CIVIL TERM
AND NOW, this
ORDER OF COURT
rHt-- day of December, 2004, following a hearing on
the merits, IT IS ORDERED:
(1) Brian A. Gregory and Deena R. Gregory shall have joint legal custody of
Olivia D. Gregory, born May 5, 2000.
(2) The mother shall have primary physical custody of Olivia.
(3) The mother may live with Olivia in Oregon or Washington.
(4) The father shall have periods of temporary physical custody of Olivia as
follows:
(a) From January 8, 2005 through February 5, 2005.
(b) During the summer of each year for six continuous weeks with those
weeks to be set by the parents not later than June 1 st of each year.
(c) Starting in December, 2005 and each year thereafter, from December
26th through January 1st.
(d) Up to one week at a time when the father can be with Olivia in the
general area in which the mother is living consistent with Olivia not missing any
school. Starting in 2005, the father may, if he chooses, exercise his period with
Olivia at Christmas in this manner.
(5) Transportation for the father's periods of temporary physical custody of Olivia
in Pennsylvania shall be paid as follows. The mother shall deliver Olivia to the father, at
her expense, at the start of such periods of temporary physical custody, and the father
shall return Olivia to the mother, at his expense, at the end of such periods of temporary
physical custody.
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By the Caurt,
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~rk W. Allhouse, Esquire
For Plaintiff
~ Stephenson Matthes, Esquire
For Defendant
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BRIAN A GREGORY
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
DEENA R. GREGORY
04-4176 CIVIL TERM
AND NOW, this
ORDER OF COURT
, 1$ ~ day of January, 2006, in anticipation of Deena
R. Gregory returning to Pennsylvania, and upon agreement of her and Brian A
Gregory, IT IS ORDERED:
(1) Upon the mother returning to Pennsylvania, the custody order of December
7,2004, is vacated and replaced with this order.
(2) Brian A Gregory and Deena R. Gregory shall have joint legal custody of
Olivia D. Gregory, born May 5, 2000.
(3) The mother shall have primary physical custody of Olivia.
(4) The father shall have temporary physical custody of Olivia as follows:
(a) During the school year:
(i) Every other weekend from Friday after school until Sunday at
7:00 p.m.
(ii) Every Tuesday and Thursday from after school until 7:30 p.m.
(iii) From 2:00 p.m. December 25th, until 7:00 p.m. January 1st
(iv) During the spring break on odd numbered years starting in
2007 (the mother shall have Olivia during the spring break in even
numbered years).
(b) During the period of each summer school vacation, from the day after Olivia
gets out of school until 5:00 p.m. the day before school starts, except that during this
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period the mother shall have Olivia every other weekend from 5:30 p.m. Friday until
8:30 p.m. Sunday, and every Tuesday and Thursday evening from 5:30 p.m. until 8:30
p.m.
(5) Both parents shall provide Olivia with her own space and bed, and personal
items.
(6) The parent having Olivia shall not consume alcohol within eight hours prior to
obtaining her and throughout that parent's period of custody.
(7) The parents may amend this agreement on a temporary basis in writing
consistent with the best interest of Olivia.
By the Court;/
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Brian A. Gregory
2121 Douglas Drive
Carlisle, PA 17013
Deena Gregory
2485 SW Elmhurst Avenu
Beaverton, OR 97005
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BRIAN A GREGORY
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
DEENA R. GREGORY
04-4176 CIVIL TERM
AND NOW, this
ORDER OF COURT
, & ~ day of January, 2006, in anticipation of Deena
R. Gregory returning to Pennsylvania, and upon agreernent of her and Brian A
Gregory, IT IS ORDERED:
(1) Upon the mother returning to Pennsylvania, the custody order of December
7, 2004, is vacated and replaced with this order.
(2) Brian A Gregory and Deena R. Gregory shall have joint legal custody of
Olivia D. Gregory, born May 5, 2000.
(3) The mother shall have primary physical custody of Olivia.
(4) The father shall have temporary physical custody of Olivia as follows:
(a) During the school year:
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EDGAR B. BAYLEY
JUDGE
I COURTHOUSE SQUARE 1387. I ~
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["=PPH Gre~1ory
24>\5 SIN Elmhurst Avenue
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RETURN TO SENDER 0
DEI.,:tve:RAe~e: AS ADCRESse:
NOT UNAeLE ro FORWARD
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BRIAN A. GREGORY, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION- LAW � C-n `
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DEENA R. GREGORY, NO. 2004-4176 CIVIL TERM °'' "'-
Defendant IN CUSTODY
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CUSTODY STIPULATION AND AGREEMENT b co c
THIS STIPULATION AND AGREEMENT entered into the day and year hereinafter set
forth, by and between Deena R. Gregory, hereinafter referred to as "Mother", and Brian A.
Gregory, hereinafter referred to as "Father."
WHEREAS, the parties are the natural parents of two children, namely Olivia D.
Gregory, born May 5, 2000, and Charles B. Gregory, born October 10, 2011, hereinafter
referred to as "Children;"
WHEREAS, the parties live separate and apart, and wish to enter into a comprehensive
stipulation and agreement relative to physical and legal custody of their children.
NOW THEREFORE, in consideration of mutual covenants, promises and agreements as
hereinafter set forth, the parties stipulate and agree as follows:
1. The parties shall share legal custody of the children.
2. Mother shall exercise primary physical custody of the children.
3. Father shall exercise partial physical custody of the children as follows:
Charles B. Gregory
a. On a two week rotating basis as follows:
i. Week one - Saturday at 5:30 p.m. to Monday at 9:00 p.m. and on
Thursday at 5:30 p.m. to 9:00 p.m.;
ii. Week two — Monday at 6:00 a.m. to 9:00 p.m. and on Thursday at 5:30
p.m.to 9:00 p.m.; and
b. At other times as the parties may agree.
Olivia D. Gre
a. At times as agreed upon between the parties.
4. The holidays will be shared as follows, with Father's periods of custody including Olivia
only if Olivia wishes to participate in said periods of custody:
a., Christmas - Every year, Mother shall exercise custody from 2:00 p.m. on
Christmas Eve to 2:00 p.m. on Christmas Day, and Father shall exercise custody
from 2:00 p.m. on Christmas Day to 9:00 p.m. on Christmas Day.
b. Thanksgiving - Every year, Father shall exercise custody from 9:00 a.m. to 9:00
p.m.
C. Easter-Every year, Mother shall exercise custody from 9:00 a.m.to 9:00 p.m.
5. Each of the parties shall be entitled to two (2) non-consecutive, or consecutive, weeks of
vacation, to take place during the summer months, with thirty (30) days written notice to
be provided to the other party, with Father's periods of custody for vacation including
Olivia only if Olivia wishes to participate in said periods of custody. The notice shall
include information as to the vacation destination and contact information for the same.
6. The receiving party shall provide transportation for all of the above periods of custody,
including holidays, except that on the routine Monday exchanges, Mother shall provide
the transportation both in the morning and in the evening.
7. Neither party shall consume any alcohol at least eight (8) hours prior to and during
his/her periods of custody.
8. The parties shall keep each other advised in the event of serious illness or medical
emergency concerning the children and shall further take any necessary steps to ensure
that the health and well-being of the children is protected. During such illness or medical
emergency, both parties shall have the right to visit the children as often as he or she
desires consistent with the proper medical care of the children.
9. Neither parent shall do anything which may estrange the children from the other party,
injure the opinion of the children as to the other party, or which may hamper the free and
natural development of the children's love and affection for the other party.
10. No party involved in this matter has participated as a party or witness or in any other
capacity or in any other proceeding concerning the legal or physical custody of the
children, except prior proceedings in this jurisdiction.
11. This Court retains jurisdiction of this matter as the parties have been residents of
Cumberland County,Pennsylvania for years.
12. No party involved in this action knows the names and addresses of any person not a party
to the proceedings who has any form of physical custody of the children or claims rights
of legal or physical custody of the children.
13. No party involved in this action, nor a member of his/her household, has been convicted,
plead guilty, or entered a plea of no contest to any of the offenses enumerated at 23 Pa.
C.S.A. Section 5329(a) or of any offense in another jurisdiction substantially equivalent
to the enumerated offenses.
14. No party shall be permitted to relocate the residence of the children to significantly impair
the ability of another person to exercise custody UNLESS every individual who has custody
rights to the children consents to the proposed relocation OR the Court approves the proposed
relocation. A person proposing to relocate MUST comply with the notice requirements
pursuant to 23 Pa. C.S.A. Section 5337(c).
15. Any modification or waiver of any of the provisions of this Agreement on a permanent
basis shall be effective only if made in writing and only if executed with the same
formality as this Stipulation and Agreement.
16. The parties acknowledge that they have read and understand the provisions of this
Agreement. Each party acknowledges that the Agreement is fair and equitable and that it
is not the result of any duress or undue influence.
17. The parties stipulate that in making this Agreement, there has been no fraud,
concealment, overreaching, coercion, or other unfair dealing on the part of the other
party.
IN WITNESS WHEREOF, the parties hereto intending to be legally bound by the terms
hereof, set forth their hands and seals the day and year hereinafter mentioned.
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WITNESSETH:
Date A. G RY
Date DEENA R. G ORY
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
On this G/ day of--4?L, , 2013, before me, the undersigned
officer, personally appeared BRIANA. GREGORY, known to me (or satisfactory proven) to be
the person whose name is subscribed to the within Agreement and acknowledged that he
executed the same for the purpose therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Alyssa J.Fomelli,Notary Public
Hampden Two,Cumberiand County P lic v �
MY Commission Ex fires March 15,2016
MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
On this N day of i
*—
2013, before me, the undersigned
officer, personally appeared DEENA R. GREGORY, known to me (or satisfactory proven) to be
the person whose name is subscribed to the within Agreement and acknowledged that she
executed the same for the purpose therein contained.
IN WITNESS WHEREOF, I hereunto set my d and official seal
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Darla K.Stephens,Notary Public Otary Public
Camp Hill Boro,Cumberland County
MY Commission Expires May 23,2014
Msmbar.PonnoYdvanD'ASSOdatlon of Notaries
a
BRIAN A. GREGORY, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
DEENA R. GREGORY, NO. 2004-4176 CIVIL TERM
Defendant IN CUSTODY
ORDER OF COURT
AND NOVA' this day of , 2013, the attached Custody Stipulation
and Agreement is hereby made an Order of Court, and all prior Orders in this matter are vacated.
BY THE COURT,
J.
cc: ZBrian A. Gregory
/ Pro Se
'---Hannah Herman-Snyder, Esquire
Hann y q
Attorney for Defendant " _ -'
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