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Home My WebLink About05-1741 v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ~ NO. ~ 17"61VIL TERM ALICIA MARIE GORSUCH, Plaintiff CHARLES JOSEPH ALLEN III, Defendant : IN CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is Alicia Marie Gorsuch, residing at 41 Garden Parkway, Carlisle, Cumberland County, Pennsylvania. 2. The defendant is Charles Joseph Allen III, residing at 730 Sterling Court, Enola, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of the following child: Name Present Residence Ace Ashton Lee Clayton Warlick 41 Garden Parkway, Carlisle, PA 17013 6 The child was not born out of wedlock. The child is presently in the custody of Mother. During the past five years, the child has resided with the following person and at the following address: Person Alicia Marie Gorsuch Address 41 Garden Parkway, Carlisle, PA Dates 03/01/00 - Present The mother of the child is Alicia Marie Gorsuch residing at 41 Garden Parkway, Carlisle, PA. She is married. The father of the child is Charles Joseph Allen III, residing at 730 Sterling Court, Enola, PA. He is unmarried. 4. The relationship of plaintiff to the child is that of mother. The plaintiff currently resides with the following persons: Name Frank Wesley Gorsuch III Tate Howard Warlick Chloe Elizabeth Gorsuch Sullivan Fox Gorsuch Relationship Husband Son Daughter Son 5. The relationship of defendant to the child is that of father. The defendant currently resides with the following persons: Name Relationship None to our knowledge 6. 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. 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. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: a) Plaintiff can provide the child with a home with adequate moral, emotional and physical surroundings as required to meet the child's needs; b) Plaintiff is willing to accept custody of the child; c) Plaintiff continues to exercise parental duties and enjoys the love and affection of the child. 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. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim NONE Wherefore, plaintiff requests the court to I verify that to best of my knowledge and belief, 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.s4904 relating to unsworn falsification to auth. orities. . - I ~1 ctJ ~..JD ~------d -Ali la Marie Gorsuch, aintiff -~ E;"" ..J::.. ~ -* ~ --=:... --- - ~ ~~ f ~. (:< ~~. r-.' ("'':''~.., ~;:J c...r'1 "'7"~. ::':; ,'~ - !.. /" ca S.: o -0 --t ...,~ -'. -."\ ,""P -r, ;-n _.C) ._..'-~~ \ '~}~; :,:,~~)~i'n .:J;c; :9:. C) r.- o ALICIA MARIE GORSUCH PLAINTIFF IN THE COURT OF COMMON PEAS OF CUMBERLAND COUNTY, PENN YL VANIA v. 05-1741 CIVIL ACTION LA W CHARLES JOSEPH ALLEN 1Il DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, April 06, 2005 __, upon consideration of th attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilr y, Esq, , the conciliator, at 4th Floor, Cumherland County Courthouse, Carlisle on Thursday, April 21, 2 05 at to:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will bc made to resol e 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 appea at the confcrence may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection I' m Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to schedule hearinf. FOR THE COURT, By: Isl Hubert X Gilroy, Esq, .. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to co ply 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 of Ice. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You ust attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. F YOU DO \lOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE T E OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL. HEL.P. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~ <~/?< b --! ~r ~~ _.. .;r/. q.1,- . ~ f' ~ ~u; 5'&7 /I/l ~ Ii? -:;2 ~'1/~,). ry 5;7 '711 ? ~ VlrJ".;r:\l,.t.,S;\!; .,I':3d JU~jnc:/'" r:~,:".(":!..::'0:NnJ 9~ :1.: !lei 9- ~dV SOOl AUilONOHiOt!d :JHl :10 381:l:l0-G31L-l ALICIA MARIE GORSUCH, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 05-1741 CIVIL TERM CHARLES JOSEPH ALLEN III, Defendant : IN CUSTODY STIPULATION FOR CUSTODY 1"11'\- . STIPULATION made this /1J?"J1_ day Of~, 2005, between Alicia M. Gorsuch, hereinafter referred to as Mother, and~J. Allen, III, hereinafter referred to as Father. WHEREAS, the above-named Mother and Father had born to them the following child on the following date: NAME Ashton Lee Clayton Warlick BIRTH DATE September 24, 1998 AND WHEREAS, the above-named Mother and Father desire to enter into a Stipulation as to the custody of the above-said child and to the partial custody rights of the non-custodial parent: NOW, THEREFORE, in order to effectuate the above purpose, the above-named Mother and Father hereby stipulate that: 1. The Mother and her husband, F. Wesley Gorsuch, III, shall have legal custody of the child. 2. The Mother and her husband shall have full physical custody of the child. 3. The Father shall have no visitation nor periods of partial custody. 4. The Father shall continue to pay child support for the child. TO THIS PURPOSE, The parties hereto intend to be legally bound by the terms of this Stipulation and desire to have the Stipulation entered as an Order of Court. ~&~~ in ay D. Baird, Esq. & / /;>./'/./M. Alicia M. Gorsuch, Mother -1J {VLi\li~.LL ~.;~,V'-'K ~.,Q.~ ('~. ^Q_ ~ ...Q.Q.....--rrf Charles J. Allen, III, Father ....~, ~ C:,) <..n -"....'. '" C.) c..:- (---, ~11 :..... i'11?~ C:j ALICIA MARIE GORSUCH, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 05-1741 CIVIL TERM CHARLES JOSEPH ALLEN III, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this { t I-l day of t11"7 1-, 2005, upon consideration of the attached custody stipulation with respect to the parties' child, Ashton Lee Clayton Warlick, born September 24, 1998, the terms of the stipulation are entered as an order of court. BY THE COURT, tU ~/! J. Lindsay Dare Baird, Esquire 37 South Hanover Street Carlisle, PA 17013 Charles J. Allen, III 730 Sterling Court Enola, PA 17025 ~ ~ j'~J:1,DS 9--, o o}l ~Cq 81 J\t~1 SUO? Ad';,'; '","-". d -~l;-{l :~T:~ ~\::-l .'r\ .->'." ----- - ALICIA MARIE GORSUCH, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 05-1741 CIVIL TERM CHARLES JOSEPH ALLEN III, Defendant : IN CUSTODY STIPULATION FOR CUSTODY ~~;J STIPULATION made this lip;, day of ,2005, between Alicia M. Gorsuch, hereinafter referred to as Mother, and~J. Allen, III, hereinafter referred to as Father. WHEREAS, the above-named Mother and Father had born to them the following child on the following date: NAME Ashton Lee Clayton Warlick BIRTH DATE September 24, 1998 AND WHEREAS, the above-named Mother and Father desire to enter into a Stipulation as to the custody of the above-said child and to the partial custody rights of the non-custodial parent: NOW. THEREFORE, in order to effectuate the above purpose, the above-named Mother and Father hereby stipulate that: 1. The Mother and her husband, F. Wesley Gorsuch, III, shall have legal custody of the child. 2. The Mother and her husband shall have full physical custody of the child. 3. The Father shall have no visitation nor periods of partial custody. 4. The Father shall continue to pay child support for the child. TO THIS PURPOSE, The parties hereto intend to be legally bound by the terms of this Stipulation and desire to have the Stipulation entered as an Order of Court. ~&c. ~ 'in ay D. Baird, Esq. ----~- ~ JJ / i / ~ > /1 ;Y-v-I . (vJv L.c.Jlv. Alicia . Gorsuch, Mother cQ~,v-'K :?. 0..0.."- ('~. ^Q_ " ....\Ja..... w Charles J. Allen, III, Father ~ c.' ~<.) ,J ,-~ .-r1 :~ ~.<. hi r h -~..~ 1".' (:) J (~: ...< 6'-:;' B~ y RECEIVED JUN 022005 ALICIA MARIE GORSUCH, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW CHARLES JOSEPH ALLEN,III, Defendant NO. 2005-1741 IN CUSTODY COURT ORDER JI AND NOW, this J I day of )t.~ ,2005, The Conciliator being advised the parties have reached an agreement, the Cone . tor relinqUIShes jurisdiction. Si:Z [I,J 2--' sonz