HomeMy WebLinkAbout05-3575p.S- 3S7, C"? l*
CUSTODY AGREEMENT
AND NOW, this day of, 2005, comes Paula R. Fox and James R. Fox
(hereinafter "Grandparents") and Jessica Nicole Fox (hereinafter "Mother") who hereby agree as follows:
WHEREAS; Mother is the natural mother of the minor child, Kye Aunna Nicole Fox bom on
March 2, 2004; and
WHEREAS, the natural father of Kye Aunna Nicole Fox is Zachary A. Barlup; and
WHEREAS, Zachary A. Barlup has not participated in the parenting of the minor child at all;
and
WHEREAS, Grandparents are the natural parents of the child's mother, Jessica Nicole Fox; and
WHEREAS, The parties hereto agree that it would be in the best interest of the minor child to be
in the custody of the Grandparents; and
WHEREAS, the parties hereto agree that the minor child has regular contact with Mother.
NOW THERFORE, in consideration of the agreement of the parties, it is hereby agreed as
follows:
1. Primary legal and physical custody of the minor child, Kye Aunna Nicole Fox
shall be with her grandparents, Paula R. Fox and James R. Fox.
2. Jessica Nicole Fox shall have regular, constant visitation and contact with the
child.
3. The parties desire that this agreement will have the full affect as a Court Order.
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
SS:
On the day of, 2005, before me, the subscriber, a Notary Public
for the Commonwealth of Pennsylvania, residing in the County of Dauphin, personally appeared
before me Paula R. Fox, and in due form of law acknowledged the above Agreement to be their
act and deed. _
i Iennifer IL tNIlson, NotaryPublic
City ofHatrisburg,DM binCOUnty
My Commission Expins Apr. 25,200
COMMONWEALTH OF PENNSYLVANIA )
SS:
COUNTY OF DAUPHIN )
On the /,?'? day of 2005, before me, the subscriber, a Notary Public
for the Commonwealth of Pennsylvania, residing in the County of Dauphin, personally appeared
before me James R. Fox, and in due form of law acknowledged the above Agreement to be their
act and deed.
, 'IARY UBLIC
NOTARIAL SEAL
ennifer M. Wilson, NotaryPublie
"icy of Harrisburg, DaupbinCOUnty
COMMONWEALTH OF PENNSYLVANIA rnmmic OnnExpiresApr. 25,2005
)
SS:
COUNTY OF DAUPHIN )
On the day of f4 p. / 2005, before me, the subscriber, a Notary Public
for the Commonwealth of Pennsylvania, residing in the County of Dauphin, personally appeared
before me Jessica Nicole Fox, and in due form of law acknowledged the above Agreement to be
their act and deed. l
NQ)?KRY PUBLIC
NOTARIAL SEAL
JenniferM Wilson Notary]?ublic
City of Hamsburg, Daupbin County
MV Commission Expires Apr. 25, 2005
WITNESS:
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Paula R. Fox
Jambs R. Fox
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J a Nicole Fox
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ORDER OF COURT
AND NOW, this day of , 2006, upon presentation of
the foregoing Agreement, said Agreement is hereby approved and entered as an Order of Court.
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JESSICA N. PATE, No. 05-3575
Plaintiff
V.
IN CUSTODY
JAMES R. FOX, PAULA R. FOX, and
ZACHARY A. BARLUP,
Defendants
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 complaint 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 WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
(717) 249-3166
NOTICIA
Le han demandado a usted en la corte. Si usted quiere 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 objeciones 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 por cualguier queja o alivio que es pedido en la peticion
de demanda. Usted puede perder dinero o sus propiendades o otros derechos importantes para. usted.
LLEVE ESTA DEMANDAA UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO
O SI NO TIENE EL DINERO SOFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONAL
O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA
ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
(717) 249-3166
& ASSOCIATES, P
Sean M. Shultz, Esquire'
Attorney ID No. 90946
11 Roadway Drive, Suite B
Carlisle, Pennsylvania 17015
(717) 249-5373
Attorneys for Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JESSICA N. PATE, No. 05-3575
Plaintiff
V.
IN CUSTODY
JAMES R. FOX, PAULA R. FOX, and
ZACHARY A. BARLUP,
Defendants
PETITION TO MODIFY CUSTODY
AND NOW, this A day of ?? 2008, comes the Petitioner, Jessica N. Fox, now
known as Jessica N. Pate, by and through her attorneys, Knight & Associates, P.C., and files the
following Petition to Modify Custody and in support thereof avers as follows:
1. The Petitioner is Jessica N. Pate, an adult individual residing at 890 Crescent
Commons Way, Apartment 201, Fayetteville, North Carolina 28314.
2. Respondents, James R. Fox and Paula R. Fox (Respondents Fox), husband and wife,
are adult individuals residing at 7615 Spring Road, Shermans Dale, Pennsylvania 17090.
3. Respondent, Zachary A. Barlup (Respondent Barlup), is an adult individual who is
believed to reside at the Dutch Country Inn, at 7620 State Route 655, Reedsville, Pennsylvania
17084.
3. Petitioner seeks a modification of the Order of Court dated July 15, 2005, a copy of
which is attached hereto and made a part hereof and marked as Exhibit "A."
4. Petitioner is the natural mother of the following minor child:
Name Present Residence Age
KyeAunna Nichole Fox (KyeAunna) 7615 Spring Road
Shermans Dale, Pennsylvania 17090 4
KyeAunna was born out of wedlock.
KyeAunna is presently in the physical custody of Respondents Fox.
In addition to the parties' present addresses, during the past five years KyeAunna has resided
with the following persons and at the following addresses:
a. From birth to July of 2006 with Petitioner, Respondents Fox, Petitioner's
siblings, David, Tasha, Chris, Dakota and Tamika Fox at 210 Second Street, Enola, Pennsylvania
17025; and
b. From July of 2006 to June 2007 with Petitioner, Respondents Fox, Petitioner's
siblings, David, Tasha, Chris, Dakota and Tamika Fox at 212 Second Street, Enola, Pennsylvania
17025.
The mother of KyeAunna is the Petitioner, Jessica N. Pate, who resides at 890 Crescent
Commons Way, Apartment 201, Fayetteville, North Carolina 28314.
The father of KyeAunna is Respondent, Zachary A. Barlup, who is believed to reside at the
Dutch Country Inn, at 7620 State Route 655, Reedsville, Pennsylvania 17084. Respondent Barlup
has not participated in the parenting of KyeAunna and has never seen KyeAunna.
The maternal grandparents of KyeAunna are Respondents, James R. Fox and Paula R. Fox,
who reside at 7615 Spring Road, Shermans Dale, Pennsylvania 17090.
5. The relationship of Petitioner to KyeAunna is that of mother. She is married to
Clayton Pate. Petitioner currently resides with her husband.
6. The relationship of Respondents Fox, James R. Fox and Paula R. Fox, to KyeAunna
is that of maternal grandparents. Respondents Fox are married to each other. Respondents Fox
currently reside with KyeAunna, their children, David, Tasha, Chris, Dakota and Tamika, their great
nephew, Lucas, and their grandson, Anthony.
7. The relationship of Respondent Zachary A. Barlup to KyeAunna is that of natural
father. Respondent Barlup's marital status is unknown and it is unknown if he resides with anyone.
8. The Petitioner has previously participated in litigation concerning custody of the
above-named child in this Court at the above-referenced docket. An Order of Court was entered on
July 15, 2005. Said Order is cited in Paragraph 3 above and is attached hereto as Exhibit "A" and
by reference incorporated herein.
The Petitioner has no knowledge of any custody proceedings concerning the custody of
KyeAunna pending before this or any other Court.
The Petitioner does not know of a person not a party to the proceedings who has physical
custody of KyeAunna or claims to have custody or visitation rights with respect to her.
9. On July 15, 2005, Petitioner signed an Agreement giving Respondents Fox primary
legal and physical custody of KyeAunna because Petitioner was entering the military and could not
have a child with her as a single parent.
10. Petitioner is on active duty with the United States Army and is no longer single.
Petitioner married Clayton Pate on March 20, 2008.
11. The July 15, 2005 Order of Court grants Petitioner "regular, constant visitation and
contact with the child."
12. At this time, Respondents Fox are refusing to allow Petitioner any contact with
KyeAunna.
13. Petitioner requests the following changes be made to the July 15, 2005 Custody
Order:
a) Petitioner requests sole legal custody of KyeAunna be awarded to her;
b) Petitioner requests primary physical custody of KyeAunna;
C) Petitioner requests that Respondents have periods of visitation for one month
every summer and at such other times as can be mutually agreed upon by the parties; and
d) Neither party shall make derogatory statements about the other parties.
14. Each parent whose parental rights to KyeAunna have not been terminated and the
person who has physical custody of KyeAunna have been named as parties to this action. There are
no other persons who are known to have or claim a right to custody or visitation of KyeAunna.
15. The best interests and permanent welfare of KyeAunna will be met if the custody
order is modified as requested because:
a) The Petitioner is a fit parent who can take care of KyeAunna;
b) The Petitioner can provide KyeAunna with a home with adequate moral,
emotional and physical surroundings as required to meet her needs;
C) The Petitioner is, and has always been, willing to accept custody of
KyeAunna;
d) The Petitioner continues to exercise parental duties and responsibilities and
enjoys the love and affection of KyeAunna.
16. To the best of Petitioner's knowledge, Respondents are unrepresented in this matter.
WHEREFORE, the Petitioner respectfully requests Your Honorable Court modify the
Custody Order dated July 15, 2005 as requested.
Respectfully submitted,
& ASSOCIATES, P.C.
man M. Shultz, Esquire \
Attorney 1D No. 90946
11 Roadway Drive, Suite B
Carlisle, Pennsylvania 17015
(717) 249-5373
Attorneys for Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JESSICA N. PATE, No. 05-3575
Plaintiff
V. IN CUSTODY
JAMES R. FOX, PAULA R. FOX, and
ZACHARY A. BARLUP,
Defendants
VERIFICATION
I verify that the statements made in the foregoing Petition to Modify are true and
correct to the best of my knowledge, information and belief. I understand that false
statements herein are made subject to the penalties of 18 Pa. C. S. Section 4904, relating
to unsworn falsification to authorities.
Pate
Exhibit "A"
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IN THE COURT OF COMMON I'UAS
OF CUMBERLAND COUN'T'Y, JPENNA,
CIVIL ACTION - LAW
CUSTODY C.
NO. D S- 357 ?s???, 1
ORDER OF COURT
AND NOW, this day of 2 upon presentation of
the foregoing Agreement, said Agreement is hereby roved and entered as an Order of Court.
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CUSTODY AGREET ENT
AND NOW, this day of ?-': , 2005, comes Paula R. Fox and James R. Fox
(hereinafter "Grandparents") and Jessica Nicole Fox (hereinafter aorne as follows:
WHEREAS; Mother is the natural mother of the minor child, Kye Aunna Nicole Fox bom on
March 2, 2004; and
WHEREAS, the natural father of Kye Aunna Nicole Fox is Zachary A. Barlup; and
WBFREAS, Zachary A. Barlup has not pa, icipated in the parenting of the minor child at all;
and
WHERF,AS, Grandparents are the natural parents of the child's mother, Jessica Nicole Fox; and
WHEREAS, The parties hereto agree that it would be in the best interest of the minor child to be
in the custody of the Grandparents; and
WHEREAS, the parties hereto agree that the minor child has regular contact with Mother.
NOW THERFORE, in consideration of the agreement of the parties, it is hereby agreed as
follows:
1. Primary legal and physical custody of the minor child, Kye Duna Nicole Fox
shall be with her grandparents, Paula R. Fox and James R. Fox.
Jessica Nicole Fox shall have regular, constant visitation and contact with the
child.
The parties desire that this agreement will have the full affect as a Court Order. r ;
C'
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
SS:
On the day of 2005, before me, the subscriber, a'Notary Public
for the Commonwealth of Pennsylvania, residing in the County of Dauphin, personally appeared
before me Paula R. Fore, and in due form of law acknowledged the above Agreement to be their
act anti deed.
' JAM, rNllsorz, N=yPUb11c
Ckyn"Harrlsbmg DmupbiaComty
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COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF DAUPHIN !
ly?
On the - 1' day of 2005, before me, the subscriber, a Notary Public
for the Commonwealth of Pennsylvania, residing in the County of Dauphin, personally appeared
before me James R. Fox, and in due; fo of law acknowledged the above Agreement to be their
act and deed.
SSOT.ARY UBLIC _--
NOTAi6 ISEIAL
, ennifer M. WASH 14awy Pablic
-ity o[HanisbMg,DMPbkCounty
,,, rn. m-nieSion Sxpim Apt 25, 2005
CO ITNIONWEALTH OF PENNSYLVANIA )
SS:
COUNTY OF DAUPHIN )
On the , day of 2005, before me, the subscriber, a Notary Public
for the Commonwealth of Pennsylvania, residing in the County of Dauphin, personally appeared
before me Jessica Nicole Fox, and in due form of law acknowledged the above Agreement to he
their act and deed.
NQ ; 'RY PUBLIC
NOTARIAL SF-A
jettnifer M. Wilson, tote.-T ??ublic
city of Hmisbinj. DauPhsn Count-l'
?y Commission Sxpirns P,or. Z5,2111
WITNESS:
Paula R. Fox
G James R. Fox ` ---'-
IAx?' icole Fox
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JESSICA N. PATE, No. 05-3575
Plaintiff
V.
IN CUSTODY
JAMES R. FOX, PAULA R. FOX, and
ZACHARY A. BARLUP,
Defendants
CERTIFICATE OF SERVICE
AND NOW, this day of*, 2008, I, Sean M. Shultz, Esquire, hereby certify that
I have this day served the following with a copy of the foregoing Petition to Modify Custody by
Certified, Restricted Delivery, Return Receipt Requested United States Mail„ addressed as follows:
James R. Fox
Paula R. Fox
7615 Spring Road
Shermans Dale, Pennsylvania 17090
Respondents Fox
Zachary A. Barlup
Dutch Country Inn
7620 State Route 655
Reedsville, Pennsylvania 17084
Respondent Barlup
Respectfully submitted,
& AS
Sean M. Shultz, Esquire /
Attorney I.D. No. 90946
11 Roadway Drive, Suite B
Carlisle, Pennsylvania 17015
(717) 249-5373
Attorney for Petitioner
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JESSICA N. FOX,
Plaintiff
V.
JAMES R. FOX and PAULA R. FOX,
Defendants
No. 05-3575
IN CUSTODY
PRAECIPE
TO THE PROTHONOTARY:
Please change the Plaintiff's name to her married name, Jessica N. Pate in the above-
captioned matter.
Respectfully submitted,
Date: August 14, 2008
KNIGHT & ASSOCIATE ,
Sean M. Shultz, Esquire
Attorney ID No. 90946
11 Roadway Drive, Suite B
Carlisle, Pennsylvania 17015
(717) 249-5373
Attorneys for Plaintiff
FAUser FolderTirm DocsTlients Files\4256.1 Jessica Pate\preecipe.2.wpd
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JESSICA N. FOX, No. 05-3575
Plaintiff :
V. IN CUSTODY
JAMES R. FOX and PAULA R. FOX,
Defendants
CERTIFICATE OF SERVICE
AND NOW, this 158 day of August, 2008, I, Sean M. Shultz, Esquire, hereby certify that
I have this day served the following with a copy of the foregoing Praecipe by first class, United
States Mail, addressed as follows:
James R. Fox
Paula R. Fox
7615 Spring Road
Shermans Dale, Pennsylvania 17097
Defendants
Zachary A. Barlup
Dutch Country Inn
7620 State Route 655
Reedsville, Pennsylvania 17084
Defendant
Respectfully submitted,
KNIGHT & ASSOCIATES, P.C.
Sean M. Shultz, Esquireu
Attorney I.D. No. 90946
11 Roadway Drive, Suite B
Carlisle, Pennsylvania 17013
(717) 249-5373
Attorneys for Plaintiff
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JESSICA N. PATE,
Plaintiff
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 05-3575
JAMES R. FOX and PAULA R. FOX,
Defendants
TO THE PROTHONOTARY:
IN CUSTODY
PRAECIPE
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Please add Zachary A. Barlup as a Defendant in the above-captioned matter.
Date: August 14, 2008
Respectfully submitted,
KNIGHT & ASSOCIATF.S_ P
Sean M. Shultz, Esquire
Attorney ID No. 90946
11 Roadway Drive, Suite B
Carlisle, Pennsylvania 17015
(717) 249-5373
Attorneys for Plaintiff
F:\User Folder\Firm Docs\Clients Files\4256-1 Jessica Pate\praecipe. 1. wpd
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JESSICA N. PATE, No. 05-3575
Plaintiff
V.
IN CUSTODY
JAMES R. FOX and PAULA R. FOX, :
Defendants
CERTIFICATE OF SERVICE
AND NOW, this 1.5-k day of August, 2008, I, Sean M. Shultz, Esquire, hereby certify that
I have this day served the following with a copy of the foregoing Praecipe by first class, United
States Mail, addressed as follows:
James R. Fox
Paula R. Fox
7615 Spring Road
Shermans Dale, Pennsylvania 17097
Defendants
Zachary A. Barlup
Dutch Country inn
7620 State Route 655
Reedsville, Pennsylvania 17084
Defendant
Respectfully submitted,
KNIGHT & ASSOCIATES, P.C.
Sean M. Shultz, Esquire
Attorney I.D. No. 90946
11 Roadway Drive, Suite B
Carlisle, Pennsylvania 17013
(717) 249-5373
Attorneys for Plaintiff
JESSICA N. PATE IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
2005-3575 CIVIL ACTION LAW
JAMES R. FOX, PAULA R. FOX, AND
ZACHARY A. BARLUP IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW, Wednesday, August 27, 2008 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, September 18, 2008 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. 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 hearing.
FOR THE COURT.
By: /s/ Hubert X. Gilroy, Es q.
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
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JESSICA N. PATE,
Plaintiff
V.
No. 05-3575
IN CUSTODY
JAMES R. FOX, PAULA R. FOX, and
ZACHARY A. BARLUP,
Defendants
TO THE PROTHONOTARY:
PRAECIPE
Please withdraw the Plaintiff's Petition to Modify filed on August 20, 2008, in the above-
captioned matter.
Respectfully submitted,
Date: September 12, 2008
KNIGHT & ASSOCIA
Sean M. Shultz, Esquire
Attorney ID No. 90946
11 Roadway Drive, Suite B
Carlisle, Pennsylvania 17015
(717) 249-5373
Attorneys for Plaintiff
FAUser FolderTirm DocslCliems Files\4256-1 Jessica fte\praecipe.l ,pd
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JESSICA N. PATE, : No. 05-3575
Plaintiff
V. IN CUSTODY
JAMES R. FOX, PAULA R. FOX, and
ZACHARY A. BARLUP,
Defendants
CERTIFICATE OF SERVICE
AND NOW, this 12`h day of September, 2008, I, Sean M. Shultz, Esquire, hereby certify that
I have this day served the following with a copy of the foregoing Praecipe by first class, United
States Mail, addressed as follows:
James R. Fox
Paula R. Fox
7615 Spring Road
Shermans Dale, Pennsylvania 17097
Defendants
Respectfully submitted,
KNIGHT & ASSOCIA
Sean M. Shultz, Esquire
Attorney I.D. No. 90946
11 Roadway Drive, Suite B
Carlisle, Pennsylvania 17013
(717) 249-5373
Attorneys for Plaintiff
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JESSICA N. PATE,
Plaintiff
v
JAMES R. FOX, PAULA R. FOX, and
ZACHARY A. BARLUP
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 266"
IN CUSTODY
Roos -3575
COURT ORDER
AND NOW, this ('"day of September,
2008, the Conciliator being advised the
Plaintiff withdraws Petition to Modify and the Conciliation Conference is no longer needed, the
Conciliator relinquishes jurisdiction.
Hubert X. Gi oy, Esquire
Custody Conciliator
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