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Home My WebLink About04-4577ALBERTA McQUAIT, Plaintiff SANDRA E. DIXON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No.7 CIVIL TERM CIVIL ACTION - CUSTODY NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the com- plaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. 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 W'~ERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 fl\cust\MCQUAITmotion ALBERTA McQUAIT, Plaintiff Vo SANDRA E. DIXON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. CIVIL ACTION - IN CUSTODY MOTION TO MAKEAGREEMENT AN ORDER OF COURT ALBERTA McQUAIT and SANDRA E. DIXON, by and through Stone LaFaver & Shekletski, move that your Honorable Court make the attached Custody Agreement dated August 19, 2004, in the above captioned action an Order of Court. ALBERTA McQUAIT . STONE LaFAVER & SHEKLETSKI fl\cust\MCQUAITagmt AGREEMENT FOR CUSTODY THIS AGREEMENT, made this ~ day of ~f~.~_Lf , 2004, by and between SANDRA E. DIXON of Harriman, Tennessee, party of the first part, and ALBERTA McQUAIT, of New Cumberland, Pennsylvania, party of the second part. WI TNES SETH: WHEREAS, the party of the first part is the mother of THOMAS A. McQUAIT, a minor, born on June 22, 1989; and WHEREAS, the father of the said minor child, Barry McQuait, is deceased (August 2, 1990); and WHEREAS, the said party of the second part is the paternal grandmother of Thomas A. McQuait; and WHEREAS, the party of the first part believes that it is in the best interest of the minor child, and therefore desires to designate the party of the second part for custody of the child in loco parentis; and -1- NOW, THEREFORE, it is agreed as follows: 1. Sandra E. Dixon, party of the first part, hereby designates Alberta McQuait, party of the second part, as Custodian of the child, Thomas A. McQuait, and hereby transfers and assigns legal custody of the said child to her, knowing that she will recurring needs and best interests. 2. Alberta McQuait, the party of the legal custody of the minor child, Thomas A. at care for the child's second part, hereby accepts McQuait, and agrees to act all times in the best interest of said child. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby, have set theirs hands and seals the day and year first above written. E. DIXON ALBERTA McQUAIT -2- STATE OF TENNESSEE : COUNTY OF ~ : ss. On this, the -~l day of ~ , 2004, before me, a Notary Public, the undersigned officer, personally appeared SANDRA E. DIXON, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that she executed the same IN WITNESS WHEREOF, year first above written. for the purposes therein contained. I have hereunto set my hand and seal ~[he day and COMMONWEALTH OF PENNSYLVANIA: : COUNTY OF CUMBERLAND : SS. On this, the /7- day of /~~ , 2004, before me, a Notary Public, the undersigned officer, personally appeared ALBERTA McQUAIT, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto year first above written. ¢OMMONW~AtlH OF I~EN, NSYLVANIA NOTARIAL SEAL I KAYE R. LUCKEY, Notary Public ~ New Cumberland 8oro. Cumberland Co. ~ My Commission Expires March 27, 2005~ set my hand and seal the day and -3- ALBERTA McQUAIT, Plaintiff SANDRA E.DIXON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : No. CIVIL TERM : CIVIL ACTION - CUSTODY NOTICIA Le hah demandado a usted en la corte. Si usted guiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objectiones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y pot cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITAABAJO PARA AVERIGUAR DONDE SU PUEDE CONSEGUIR ASISTENCIALEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 -2- fl\cust\MCQUAITcomplaint ALBERTA McQUAIT, Plaintiff SANDRA E. DIXON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION CUSTODY COMPLAINT FOR CUSTODY residing at 112 Rosemont Avenue, New Cumberland, Pennsylvania 17070. 2. The defendant is SANDRA E. DIXON, residing at 1424 Margrave Drive, Harriman, The plaintiff is ALBERTA McQUAIT, an adult individual, Cumberland County, an adult individual, Tennessee 37748. 3. Plaintiff seeks custody of THOMAS A. McQUAIT, who resides at 112 Rosemont Avenue, New Cumberland, Cumberland County, Pennsylvania 17070, is 15 years of age having been born on June 22, 1989. The child was born out of wedlock. The child is presently in the custody of Alberta McQuait who resides at 112 Rosemont Avenue, New Cumberland, Cumberland County, Pennsylvania 17070. During the past five years, the child has resided with the following persons and at the following addresses: -1- Sandra NAME E. Dixon ADDRESS 1424 Margrave Drive Harriman, TN 37748 DATES 6/22/1989 to 7/2/2004 The mother of residing at 1424 She is The 4. The grandmother. persons: NAME Crystal Evans, 28 years of age the child is Sandra E. Dixon, Margrave Drive, Harriman, Tennessee married. father of the child is Barry A. McQuait, relationship of plaintiff to the child is The plaintiff currently resides with the currently 37748. deceased. that of following RELATIONSHIP Granddaughter another capacity, in other litigation child in this or another court. Plaintiff has not participated as a party or witness, or in concerning the custody of the 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. -2- served by granting the relief requested because plaintiff stable living environment for said child. 7. Each parent whose parental rights terminated and the person who has physical been named as parties to this action. WHEREFORE, plaintiff requests the court child. The best interest and permanent welfare of the child will be can provide to the child have not been custody of the child have to grant custody of the STONE LaFAVER & SHEKLETSKI Supreme Court I.D. ~40486 414 Bridge Street, P.O. Box E New Cumberland, PA 17070 Telephone: (717) 774-7435 Attorneys for Plaintiff -3- VERIFICATION ALBERTA McQUAIT, states that she is the Plaintiff named in the foregoing instrument and that she is acquainted with the facts set forth in the foregoing instrument; that the same are true and correct to the best of her knowledge, statement is made subject to relating to unsworn falsification to information and belief; and that this the penalties of 18 Pa. C.S.A. ~ 4904 authorities. ALBERTA McQUAIT fl~cust \ 1AGREMNTORD SEP 1 ~ 2~ ~ ALBERTA McQUAIT, Plaintiff Vo SANDRA E. DIXON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - IN CUSTODY ORDER AND NOW, this !~.t~day of consideration of the foregoing motion, Child between the parties dated August is hereby incorporated into the above captioned action Order of Court. , 2004 upon the Custody Agreement for Minor 19, 2004, and attached hereto and made an BY THE COURT: Jo ~0