HomeMy WebLinkAbout05-6398
SAIDlS
SHUFF, FLOWER
& LINDSAY
AlTORNEYS-ATeLAW
26 W. High Street
Carlisle, P A
ADRIENNE SU,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - Lf.\W
NO. 0 '/. t,,3 9 F CIVIL 2005
DARRACH DOLAN,
Defendant
IN CUSTODY
COMPLAINT FOR CUSTODY
AND NOW come Darrach Dolan and Adrienne Su by and through their counsel,
Lindsay Baird, Esquire and Carol J. Lindsay, Esquire, and petition this Honorable Court as
follows:
1. The parties are Adrienne Su, residing at 223 West Pomfret Street, Carlisle,
Cumberland County, Pennsylvania and Darrach Dolan, residing at 254 Arch Street, Carlisle,
Cumberland County, Pennsylvania.
2. The parties are children of two children: Aisling Dolan, born October 24, 2000,
and Dervla Dolan, born November 7,2003.
3. The parties have entered in an Agreement for the custody and parenting of
the parties' children.
4. The parties seek entry of their Agreement as a Court Order and, to that end,
the Petition is filed by counsel for Plaintiff. Defendant concurs in its filing.
SAIDIS, SHUFF, FLOWER & LINDSAY
f) "
SAlOIS
SHUFF, FLOWER
& LINDSAY
ATTORNEYS-AT-LAW
26 W. High Street
Carlisle, P A
II
VERIFICATION
I verify that the statements made in the foregoing document are true and
correct. I understand that false statements herein are made subject to the penalties
of 18 Pa. C.S 94904, relating to unsworn falsifications to authorities.
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Adrienne Su
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Date:
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SAlOIS
SHUFF, FLOWER
& LINDSAY
ATIORNEYS.Ar-LAW
26 W. High Street
Carlisle, PA
II
ADRIENNE SUo
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - l_AW
NO. 05', b3Yl"'CIVIL 2005
v.
DARRACH DOLAN,
Defendant
IN CUSTODY
STIPULATION FOR CUSTODY
The parties hereto stipulate as follows:
1. They are the parents of Aisling Dolan, born October 24, 2000, and
Dervla Dolan, born November 7,2003.
2. On July 29, 2005, the parties signed a Property Settlement and
Separation Agreement which they negotiated in the collaborative process. A part of
that Agreement dealt with the legal and physical custody of the parties' children and
is incorporated herein. The parties understand that they may make use of the
collaborative process to change arrangements and may do so at any time.
3. The parties desire to stipulate to the entry of their Agreement as an
Order of Court.
4. The parties will share legal and physical custody of Aisling and Dervla.
5. The children will reside at the parties' respective homes in Carlisle, PA
and attend day care as the parties can agree.
6.
Transfer of the children will be accomplished by the parent who had
the children overnight dropping them off at daycare and the other parent picking
them up after school.
12/13/2005 0B:57
71 72436510
SAIDIS SHUFF FLOWER
PAGE 04/04
7. If either party travels with the children outside of the Commonwealth of
Pennsylvania, he or she will return the children to the Commonweaft!1 at the end of
the agreed upon vacation.
8. The parties desire that the terms of this Agreement be entered as an
Order of Court.
Witness:
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Darrach Dolan
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SAlOIS
SHUFF, FWWER
& LINDSAY
A1TORNEYS.AT-LAW
26 W. High Street
Carlisle, P A
II
ADRIENNE SU,
Plaintiff
v.
DARRACH DOLAN,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 05-6398 CIVIL 2005
IN DIVORCE
ACCEPTANCE OF SERVICE
I accept service of the Custody Complaint in the above-captioned matter and certify
that I am authorized to do so.
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SAlOIS
SHUFF, FLOWER
& LINDSAY
ATIORNEYS.AT-LAW
26 W. High Street
Carlisle, PA
II
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ADRIENNE SU,
Plaintiff
v.
DARRACH DOLAN,
Defendant
AND NOW, this
\
DEe 1 fj 2005
IN THE COURT OF COMMON PLEAS ,).Iii
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO.:;5'~58f CIVIL 2005
IN CUSTODY
ORDER OF COURT
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"2 I day of '])~
, 2005, upon
consideration of the within Stipulation, the terms thereof are hereby made an Order
of Cou rt.
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BY THE COURT,
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