HomeMy WebLinkAbout02-0976ALLAN L. JONES and : IN THE COURT OF COMMON PLEAS OF
GALE E. JONES, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
v : NO. 02 - q r* CIVIL
RODNEY A. HILL, : CIVIL ACTION- LAW
Defendant : IN CUSTODY
STIPULATION
The parties hereby agree and stipulate as follows:
1
The Plaintiffs Allan L. Jones and Gale E. Jones are husband and wife and reside at 129 Darr
Avenue, Carlisle, Cumberland County, Pennsylvania.
2
The Defendant Rodney A. Hill is currently incarcerated in Cumberland County Prison at
Carlisle, Pennsylvania.
3
Rodney A. Hill (hereinafter referred to as "Father") is the father of Kourtney A. Hill born July
29, 1992.
4
The Mother of Kourtney A. Hill was Tracy L. Jones, the daughter of the Plaintiffs, who died
on January 15, 1995.
5
The minor child Kourtney A. Hill is currently in the custody of her maternal Grandparents, the
Plaintiffs herein.
The parties agree that the court can enter an order in the form as attached hereto.
WITNESS
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Allan L. Tones
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Gale E. Jones
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Rodney A.Aill
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MAR 0 5 ?002 0.,
ALLAN L. JONES and : IN THE COURT OF COMMON PLEAS OF
GALE E. JONES, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
v :NO. 02 - gt7G CIVIL
RODNEY A. HILL, : CIVIL ACTION- LAW
Defendant : IN CUSTODY
COURT ORDER
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AND NOW, this %- day of 2002, upon consideration
of the attached Stipulation, it is ordered and directed as follows:
1. The Maternal Grandparents, Allan L. Jones and Gale E. Jones, shall enjoy legal and
physical custody of Kourtney A. Hill, born July 29, 1992.
2. The Father, Rodney A. Hill, shall enjoy liberal periods of temporary custody with
the minor child at such times as agreed upon by the parties.
3. In the event either party desires to modify this order and the parties are unable to
reach an agreement with respect to a modification, either party may petition the
court to have this order modified.
4. Father's periods of temporary custody shall include Father's ability to have
telephone contact with his minor child and the obligation of the Maternal
Grandparents to keep Father advised with respect to all matters relating to the
health, education and best interests of the minor child.
BY
By:
?Hubert X. Gilroy, Esquire n6?1?9 y?
Attorney for Plaintiffs L (' 7
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1 Rodney A. Hill 03
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ALLAN L. JONES and : IN THE COURT OF COMMON PLEAS OF
GALE E. JONES, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
v : NO. 02 - q 7Cp CIVIL
RODNEY A. HILL, : CIVIL ACTION- LAW
Defendant : IN CUSTODY
STIPULATION
The parties hereby agree and stipulate as follows:
1
The Plaintiffs Allan L. Jones and Gale E. Jones are husband and wife and reside at 129 Darr
Avenue, Carlisle, Cumberland County, Pennsylvania.
2
The Defendant Rodney A. Hill is currently incarcerated in Cumberland County Prison at
Carlisle, Pennsylvania.
3
Rodney A. Hill (hereinafter referred to as "Father") is the father of Kourtney A. Hill born July
29, 1992.
4
The Mother of Kourtney A. Hill was Tracy L. Jones, the daughter of the Plaintiffs, who died
on January 15, 1995.
5
The minor child Kourtney A. Hill is currently in the custody of her maternal Grandparents, the
Plaintiffs herein.
6
The parties agree that the court can enter an order in the form as attached hereto.
WITNESS
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Allan L. ones
Gale E. Jones
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R6dney A.11
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Created. 9 '0 OS 0:0nPb1
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Hubert X. Gilroy, Esquire
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
I.D. 29943
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiffs
ALLAN L. JONES and IN THE COURT OF COMMON PLEAS OF
GALE E. JONES, CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff :
VS. CIVIL ACTION - LAW
RODNEY A. HILL, NO. 2002-976
Defendant IN CUSTODY
STIPULATION
The parties hereby stipulate as follows:
The Plaintiffs, Allan L. Jones and Gale E. Jones, are the maternal grandparents of
Kourtney A. Hill born July 29, 1992.
2. The Defendant, Rodney A. Hill, is the natural father of the minor child.
3. The mother of the minor child was Tracy L. Jones, daughter of the plaintiffs, who
died on January 15, 1995.
3. The parties previously entered into a stipulation agreeing the maternal grandparents
would have custody of the minor child and that stipulation was incorporated as a
Court Order on March 5, 2002.
4. The parties desire to modify the prior Court Order in light of the fact that the minor
child is residing with her father and the parties want to insure that the maternal
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grandparents have no rights or obligations relative to any status a
having custody of the minor child, s custodian or
5. The parties agree that the Court can enter an Order in th
form as attached hereto.
WITNESS:
4.
ALLAN L. JONES ?.
GALE E. JONES
RODNEY . HILL
DATE: December
__, 2008
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Created: y,.0 04 O: OOPM 11 ' !F O 10 L /? ?!N
?. Rotsed. 11'_x05 1049AM 1- VVIJ
Hubert X. Gilroy, Esquire
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
I.D. 29943
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiffs
ALLAN L. JONES and IN THE COURT OF COMMON PLEAS OF
GALE E. JONES, CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
vs. CIVIL ACTION - LAW
RODNEY A. HILL, NO. 2002-976
Defendant IN CUSTODY
COURT ORDER
AND NOW, this tt day of December, 2008, upon consideration of the attached
Stipulation, it is ordered and directed as follows:
1. This Court's prior Order of March 5, 2002, granting the maternal grandparents, Allan
L. Jones and Gale E. Jones, legal and physical custody of Kourtney A. Hill born July
29, 1992 is vacated.
2. The father, Rodney A. Hill, shall enjoy legal and physical custody of Kourtney A.
Hill born July 29, 1992. __0
BY THE
cc: ?bcrt X. Gilroy, Esquire
?Xdney A. Hill 1
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Judge Edgar B. Ba
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