HomeMy WebLinkAbout06-2955
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THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
FAMILY DIVISION tI3J
1180 days = \ \ l => Oll
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del (j C - 2Ji 55' Ct .id
Petitioner
Case number:m. M 53 -_CQL
Respondent
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~ '. QRDER FpRc;enerations EOLJCA TION/ME:DIATION ,SEMINAR
And naw, to. wit, this I Cr'ili day af , 20tx., it is hereby ordered and decreed
as follows: Both parties in the above captianed m t r shall attend one (1) educational seminar an
Scti:q'^"'-.ll \0"" ,20~at erOO (amfpm) at the WiQhtman Schaal Communitv Buildina. Any
rescheduling shall be arranged thraugh the Generatian office at 412-350-4311 and the education
seminar must be completed priar to. tile scheduled mediation session date.
Child ar children af the parties are as fallo.~s.:q
i f.'t!;~t~n 1II Ag"tl ;~~:,~" C",~~h
3.
4.
Except as nated be law, the abave na'medchild ar children are ordered to. attend the children's
interactive group simultaneaus with the adult parties attending the adult education seminar. Children
under the age of six (6) years or aver 15 years arl:! exemptfrom attending., " ,. ",.. ,.. ..
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Payments by the moving partY for Genllratians education seminar and mediation session
must be made at the time of filing.
The movlnQ pam {Petitioner} shall be respansible to pay:
1. The Prathonotary filing fee
2. His/her education fee ($40 for the filing party)
3. His/her half of each child's educatianfee if appropriate ($30 total far each child
between the ages of 6-15 years old = $15/per child per party)
4. His/her mediation fee ($100 for the filing party)
All costs paid into Generations by the Petitianer (fUing party) shall be made payable to. the Allegheny
County Treasurer in the farm af a money order, cashier's, certified, or attorney law firm check AT
THE TIME OF FILING. NO CASH OR PERSONAL CHECKS SHALL BE ACCEPTED BY
GENERATIONS.
j,/rned order
.' 'I
The non-movina partv (Respondent) shall be responsible to pay:
1. His/her education fee ($40) for their participation and must be paid to the Generations
office seven days prior to attending the scheduled education seminar.
2. His/her half of each child's education seminar fee, if appropriate ($15 per child
between the ages of 6-15 years old and shall be paid a minimum of seven days prior to attending the
seminar).
3. His/her mediation fee ($100) to be paid to the Generations office a minimum of seven
days prior to the scheduled mediation session.
Acceptable forms of payments are money order, cashier's, certified, or attorney law firm check.
Respondent's payments to be made to the Generations office at Generations 440 Ross Street 1"
floor, Pittsburgh, Pa. 15219, payable to the Alleahenv County Treasurer.
NO CASH OR PERSONAL CHECKS SHALL BE ACCEPTED BY GENERATIONS.
Attendance at the education seminar is mandatary and, upon completion, attendees will receive
a certificate of completion which may be requested by the Court at a later date. Seminars are restricted
tothe parties and children assigned. No third parties shall be permitted toattend. Completion of the
education seminar will be required to proceed to thE! mediation session.
The Generations mediation session is scheduled for .."J 9.. 01 J f)n':JJlt ,20.Q~
at I' .\l(\ (a~ The mediation session shall be conducted $t Generations 440Rbss Street 1 " floor.
Failure to appe)rfor the mediation session will result in forfeiture of fees paid.
The court will not compel a mediation session in a case where either a party or child of either
party has been the subject of domestic violence or child abuse within the past 24 months. A formal
waiver request is available and must be submitted to the Generations Center no later than seven days
prior to the scheduled mediation session. The submission of a domestic violence waiver does
not excuse any Darty from participation in the education seminar. Parties may arrange to -;U;nd
separate classes when a domestic violence waiver has been submitted. .
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Security notice: .
1. NO THIRD PARTIES. ATTORNEYS OR CHILDREN ARE PERMITTED IN GENERATIONS
DURING A MEDIATION SESSION.
2. ATTORNEYS SHALL ONLY BE PERMITTED IN THE GENERATIONS UNIT FOR
CONCILIATIONS ONLY.
3. CHILDREN WILL NOT BE PERMITTED IN GENERATIONS FOR CONCILIATIONS OR
MEDIATION SESSIONS.
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6/112005 ed/med order
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IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY. PENNSYLVANIA
FAMILY DIVISION
S~{Z'E+t<[.
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Plaintiff
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7\'1 CrlQr1<:j
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Defendant .
VERIFICATION
~ The adults and/or child{ren) involved in this matter are not now nor have
they ever been involved in a Juvenile Court proceeding or with Children,
Youth and Families (CYF).
CI The adults and/or child(ren) involved in this matter are CURRENTLY
INVOL VED in a Juvenile Court proceeding at No. or with
Children, Youth and Families (CYF). EXPLAIN INVOLVEMENT BELOW.
The Caseworker is whose phone
lumber is .
V The adults and/or child{ren) involved in this matter have PREVlOUSL Y
been involved in a Juvenile Court pr()ceedingat No. or with
Children, Youth and Families (CYF). EXPLAIN INVOLVEMENT BELOW
The Caseworker was
whose phone number is
Qrm~-i~)
The involvement in the case is or
. E" ~ ? I /" ! " I
was. ~/~ '/,-"(/11 c ,-,(.t'e jt/c;" /,;c:__ ('- JO'>.
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The case was closed on
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I verify that the statements made in this Verification are true and
correct. I understand that false statements herein are made subject to the
penalties of 18 Pa C.S.A. Section 4904 relating to unsworn falsification to
authorities.
~!) Je'\/
Date:,) /5/('10
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,/ Plaintiff
CONFIRMATION OF CUSTODY 1/1106
Page 1 of 9
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IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
FAMILY DIVISION
'511 lr-le.\/ ])AntdS
/ Plaintiff
V. Case Number: FD
Rid)() H..~ IV/orr 1'5 Jr. ,
Defendant
E~-er-g-en C-y
COMPLAINT FOR C~FIRMATION OF
CUSTODYI
COMPLAINT FOR CUSTODY
Filed on Behalf of:
Name:
SU7c-ff-( Doni ek
3/9 Euel r/ IlPf'
6/(:/55;70/--; h,. 150(!S
(C//) k/l d ~ lji/ t-J
Address:
Phone:
CONFIRMATION OF CUSTODY 111106
Page2of9
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NOTICE OF PRESENTATION AND CERTIFICATE OF SERVICE
TO: '"R\(\1J yrLJv\nyn~ ~ '(.
PLEASE TAKE NOTICE that the within Petition shall be presented to the Pro Se
Motions Judge, Adult Section, Family Division, Court of Common Pleas,
Alleghelgounty, Third Floor, Room 3009,440 Ross Street, Pittsburgh, PA on
the. day of IL..~ . , 2006 at 1:30 P.M.
I hereby certify that a true and correct copy of the within Petition and Notice of
Presentation was served upon Defendant by depositing the sure in the U.S. Mail,
First Class, postage prepaid on the I€f' day of ,~ off . _, 2006
to the address listed below. I
~.~~
Family Division Pro Se Coordin tor
I verify that the address provided by me and set forth below is the last
known address of the Defendant herein.
Clo I j nOn VYI (\,(Yl'~
5b~ m C' lf1c it( e.
3 \0 ~sVm t \h J56t.f~
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/!.!/y~vC IJ )JnfL ';l
Plaintiff
CONFIRMATION OF CUSTODY 1/1/06
Page 30f9
NOTICE TO DEFEND
You have been sued in court regarding custody of your children. If you fail to appear as
provided by this order, an order for custody, partial custody or visitation may be entered
against you or the court may issue a warrant for your arrest.
YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IFyOU
CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE
YOU WITH INFORMA nON ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES
TO ELIGIBLE,PERSONS AT A REDUCED FEE OR NO FEE.
LAWYER REFERRAL SERVICE
920 CITY COUNTY BUILDING
PITTSBURGH, PA 15219
(412) 261-5555
AMERICANS WITH DISABILITIES ACT OF 1990
The Allegheny County Court of Common Pleas Family Division is required, by law, to comply
with the Americans with Disabilities 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 Family Division. You must attend the scheduled hearing.
ONLY THE PARTIES AND THEIR ATTORNEYS SHALL BE PERMITTED IN THE
GENERATIONS OFFICE ON THE FIRST FLOOR, FAMILY COURT FACILITY, 440 ROSS
STREET. CHILDREN WILL NOT BE PERMITTED IN CONCILlA nON OR MEDIA nON
SESSIONS, NO ATTORNEYS WILL BE PERMITTED IN MEDIATION SESSIONS.
CONFIRMATION OF CUSTODY 1/1/06
Page 4 of 9
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IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
FAMILY DIVISION
71
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Plaintiff
v.
Case Number: FD
\~ \ C \, 0 fC\h ~)\ 0 r' r ) ~ J r,
Defendant
COMPLAINT FOR CONFIRMATION OF CUSTODY/COMPLAINT FOR CUSTODY
1. Plaintiffs name: SU?E tIc Dc ,) 1 C ( s
::~~~;~i~;::;:~~h;:// ~~::c/ 11 v. C
2. Defendant's name: R,chclr-dLllDrrrCS, J'r.
Residential Address: IlH O'lt-I't krvow A-ddr"o:,s
" met-Ii ~,'" I It/ 171C r
D f d t' D t f B rth :)'0.3 f>ncI-fI{:t,:.. A v",,_
e en. an s a eo i ~ ~"""'(JC''''' t''' Is"";'
3. Plaintiff seeks confirmation of custody of the following child(ren):
Name Present Residence
. ""Ie '3!,1[:.-i-'C I,d A"I:: b\us:,
ebe C(; IOfTIS 19 Euc/,d
a. The child(ren) (was, ~ (was not, were not) bom out of wedlock. .~
b. The child(ren) (is, ~i presently in the custody of ~ I c:: h ch,d ]V\e r Ilj(la~
" .
who,se relationship is fa +iJ i.", . residing at tic.. it> 6 J:; is\' h ,t cL e '<.-
J;/-If/f'n5bUY I~A./O -:F DtJl>'f fr.'Nt'iJ hiS t'd~res5~'. '.'..
--r:-- };:"iJ"'lJ I(J !ni.,rhr-."" L-/4/du, ,f)orrJ~. 5 c? fA('jt4l~'L /'.11 c")''-
GLRS<':J,..-i fJ:;. /-) 0 ,-:)
CONFIRMATION OF CUSTODY 1/1106
Page 5 of g
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c.
During the past five (5) years, the child(ren) ~has,
following persons at the following addresses: '
Name Address
<: l)1' "f" ~)G Y'1 ,c: I:: 3/9Z(,/(/~(/ .fIX:
have) lived with the
Dates
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d. The mother of the child(ren) is 5 {j ;?(' lit D4'1;' f' /< , and she currently
lives at '';,)<1 c.ur/ld ILe: 6!c.S5Pct f /:j",. /.5(: f/s-
(;... /
e. She is presently ( )married, ( )divorced, (tr)Single. (check one)
f. The father of the child(ren) is 5u?el/e Dcr;7,'e/~ and he currently
I. t' b 0
Ives a !lJ4V('IS u";' i~,
.
PI,~)tI(WD"" ""cl'~ Ae /..:,
g. He is presently (..)married, ( )divorced, ( ) single. (check one)
4. The relationship of Plaintiff to the child(ren) is that of ,('1 \ ,,1 ), -<. ,7
The Plaintiff currently resides with the following persons:
Name' Relationshio
_ISUL' Ny.' f)anlc!S) ILld ClUe:..
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I) klA c,
5. The relationship of Defendant to the child(ren) is that of r c{ t j, *-..-
The Defendant currently resides with the following persons:
Name Relationshio
lU' be-, ~ #J"~r,....-A~~.,,~ .....> lNl t:e
(rilPlaintiff ( )has ( ~as not participated as a party or witness, or in another capacity, in
l./~ther litigation concerning the custody of the child(ren) in this or another court.
If yes, the court, tenm, number and the relationship to this action is: '
OPlaintiff ( )has (~as no infonmation of a custody proceeding conceming this child(ren)
pending in a court of this commonwealth,
If yes, the court, tenm, number and the relationship to this action is:
CONFIRMATION OF CUSTOOY 1/1/06
Page 6 of g
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Plaintiff j,()knows (~oes not know of a person, not a party to the proceedings, who
has physical custody of the child(ren) or claims to have custody or visitation rights with
respect to the child(ren). n..
~,thenameand~~~~~.F
7. The best interest and permanent welfare of the child will be served by granting the
relief requested because (set forth facts showing that the granting of the relief requested will be in
the best interest of the child(ren):
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CJ ern 1. .
8. Each parent whose parental righ s to t chil (ren) has/have not een terminate an
the person who has physical custo~y of the child(ren) has been named as party to this
action. All ather persons, named Ii>elow, who are known to have or claims a right to
custody/visitation of the child(ren) 'have been given notice of the pendency of this
action and the right to intervene:
Name
9. Plaintiff requests standing to proceep with this custody action.
WHEREFORE, Plaintiff requests the court grant confirmation of custody of the
children to Plaintiff. In the case of a third party requesting confirmation, Plaintiff
respectfully requests standing to proceed
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. ,;-oj Plaintiffs Signature
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Date
I verify that the statements made in this Petition are true and correct. I
understand that false statements herein are made subject to the penalties of 18
Pa.C.S.A. ~4904 relating to unsworn falsification to authorities.
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laintiffs Signature
CONFIRMATION OF CUSTODY 1/1/06.
Page 1 of g
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IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
FAMILY DIVISION
,9u ~f H C. ~()a V1 i' -of Ls
Plaintiff
v.
fl-lc~rd.J
Case Number: FD
Jf-lorrI'Sj;fr-- ,
Defendant'
l'
ORDER OF COURT
CONFIRMATION OF CUSTODY
AND NOW, this
day of
presentation he Complaint for Confirmation of Custody, it is hereby ORDE
1. Confi ation of primary custody of the child(ren) (insert names d date of birth):
is granted to Plaintiff (Mot r) (Father) (Grandparent) (Aunt who resides at the
address set forth in the Petition.
2. The Defendant's right modify this order is pr served.
3. The Generations Program waived.
4.
Plaintiff is responsible for the
ary filing fee for this Petition unless
an In Forma Pauperis petition has been grante<;j",
fi
r .
5. The court will vacate this ol}ler if made a re there is an existing custody
i'
order of court in effect. .i "
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6. In the case of a thil'Cfparty litigant, standing is hereq granted.
if
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7. The foregoing Complaint states a claim upon which re
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,l' By the Court,
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CONFIRMATION OF CUSTODY 1/1/06
Page 8 019
IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
FAMILY DIVISION
Su ~1"f/-(
~ttll t:{s
NO.6 f) -fJ(J~9S~ -001
VS.
t Ie [1 Ct. rc)
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Defendant )
INTERIM ORDER OF COURT
..rtlt ~c.t
1. Confirmation of Custody is denied due to Ddv, ,d'dl II S C;Ulllc",1. T c,~ c.~
2. Case is referred to Generations on the Custody Complaint.
3. pending,further Order, custody of the child~e~ awarded on an
interim basis t€oth3 (Father) (Matemal Grandmother Grandfather) (Paternal
Grandmother Grandfather) (Maternal Aunt) (Paternal Aunt) with partial custody
granted to (Mother) (Father) as follows:
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4. The foregoing Complaint states a claim upon which relief may be granted.
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5. In the case of a third party litigant, standing is hereby granted. ~
B THE COURT:
CONFIRMA
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IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY. PENNSYLVANIA
FAMILY DIVISION
5u :c--1fr: \)C<f\ " e Is
Petitioner
v.
Case Number: FD
l'.J. 1 i\/l . -0'
l\vncrO \' ()f~""IS
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Respondent
E 11\V~ .
PETITION FOR WAIVER OF
PROTHONOTARY FEES AND
GENERATIONS FEES AND IMPOSING
GENERATIONS FEES ON OPPOSING
PARTY
Filed on Behalf of:
Name '5[; P (:JIC Dt/I'JI ~ I:;
Address 3/;/ Euc/;(III&'('
(-/055j")O( I- /?:i. / 5(/ V)
Phone: tit!) ia-// Y ?
IFP Generations1/23/06
1 afa
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NOTICE OF PRESENTATION AND CERTIFICATE OF SERVICE
TO: R, (harr/ 1 . !I/lorn 5 Jr.
PLEASE TAKE NOTICE that the within Petition shall be presented to the Pro Se
Motions Judge, Adult Section, Family Division, Court of Common Pleas,
Allegheny County, Third Floor, Room 3009, 440 Ross Street, Pittsburgh, PA on
the .11-1 day of. , 2006 at 1 :30 P.M.
1'8'
I hereby certify that a true and correct copy of the within Petition and Notice of
Presentation was served upon Respondent by depositing the same in the U.S.
Mail, Fi~tt ~Iass, postage prepaid on the I :? tv, day Of~,
2006 to t~address listed below.
I~ (-t
Family Division Pro Se Coordi tor
I verify that the address provided by me and set forth below is the last
known address of the Respondent herein.
C/D Lindo Morris
tiD ~ POCI~( .Att
~\n~~~ th /5')Lff
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,,1~v< Ii j) idh&C('
Petitioner
IFP Generations1/23/06
2018
IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
, FAMILY DIVISION
<)\.))E Yty: '\)CJ. n 'j (~~ \ S
Petitioner
v. Case Number: FD
R.chc((\ lr )V\ortlS Jr.,
Respondent
COUNT I
PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS
AND NOW, comes the Petitioner, a party in the above captioned custody
proceeding, who respectfully requests this Honorable Court grant Petitioner leave to
proceed In Forma Pauperis in the above-captioned case and in support thereof, avers
as follows:
1. Petitioner desires to file an action for custody, but is without the funds to
pay the filing fee and/or the Generations fees.
2. Petitioner's financial affairs are set forth in a verified statement, a copy of
which is attached to this Petition as Exhibit A.
3. If Petitioner is not permitted to proceed In Forma Pauperis, Petitioner will
be denied due process of law and/or rights under the Constitution of the United States
and the Constitution of the Commonwealth of Pennsylvania.
WHEREFORE, Petitioner prays this Honorable Court grant this Petition and to
allow this action without payment of the required fees.
IFP Generations1f23/06
3018
/
COUNT II
PETITION TO WAIVE GENERATIONS' FEES
OR IMPOSE SUCH FEES ON OPPOSING PARTY
AND NOW, comes Petitioner, a party in the above-captioned custody
proceeding, and in support of this motion avers as follows:
1. I am required to pay $ 1'5<;" in education fees and $100 in mediation
fees in connection with this custody action.
2. I ( {am ( lam not the moving party in this action.
3. As set forth in the attached Verified Financial Statement, I cannot afford to
pay the education/medication fees.
4. The other party owes support or arrearages in the amount of $ ~Lc I. Fj '+.
WHEREFORE, Petitioner requests the court impose the Education/Mediation
fees upon the other party or waive such fees.
I verify that the statements made in this Petition are true and correct. I
understand that false statements herein are made subject to the penalties of 18
Pa.C.S.A. 94904, relating to unworn falsification to authorities.
).1 Z 'O(P
Dale
j,~/~ j) tL~
.. Petitioner's signature
IFP Generalions1123/06
4018
IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
FAMILY DIVISION
5V)t1!r:. Do,) / \.r::'
Petitioner
v. Case Number: FD
R,c h c; ,d 1..., /'-'le:, I !~ ,sJI-'
Respondent
VERIFIED FINANCIAL STATEMENT
(ill am the Petitioner herein, and because of my financial condition am unable to
pay the-fues and or cost of prosecuting or defending this litigation.
rev I am the Petitioner herein, and because of my financial condition am unable to
pay the education and/or mediation fees for the Generations Program.
(3.\ I am unable to obtain funds from anyone, including my family and associates
to payiFl'e costs of this litigation.
€,i I represent that the information below relating to my ability to pay the fees and
costs is true and correct:
a.
Name:
Address:
'r ~il~r'~e ~G/};'~) )5
f' / ~{/(- "r/ live
6-/0 c;r:;PC'/'T /70. ,.G~C/'S"'"
I
b. Emplovment: @
Are you presently employed? YES . (cirdeone) (' s sri
Employer's name:
Employer's address:
Salary/wages per month:
Type of work:
If you are presently unemployed, state:
Date of last employment: '1'\ la
Salary/wages per month:
Type of work:
I FP Generations 1 /23/06
5 of 8
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Dividends:
Workman's compensation:
Public Assistance(DPW):
Other:
d. Other contributions to household support ( )wife ( )husband
( )Other:
If the above checked person is employed, provide name of employer:
Salary/wages per month:
Contributions from children:
Other contributions:
e. Property owned:
Cash: iJi) .
Checking/Savings account;
Certificates of deposit:
Real Estate (including home):
Motor vehicle: Ly'?
Cost:
Stocks and/or bonds:
Other:
Year and Model: dCOD ,'\e,k" i ("V1~
Amount owed: 'fu~co
N~
f. Debts and obligations:
Mortgage: WON, Rent:
Loans: ,
Other: (l:)1.u.tl'O ^ , COJI l Y1<;lI IJCl/\t1a ) cnll piUj ~1'1 O'V1 .t:-
g. Persons dependent upon you for support:
Spouse: (name) 1\,'" ^' e.
Children: (if any)~ame:
~~ ~}~Tt-L
' . . . \) '1 <
~dl(l/lr\ ')l"e.
l-fro'Yll~ c,,-€e...
ager
it
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Other persons:
DClIY\..WS
1 g mo*h.s
IF? Generationsll23/06
60f8
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5. I understand that I have a continuing obligation to inform the
Court of improvement in my financial circumstances which would permit me to
pay the costs incurred herein.
6. I understand that this In Forma Pauperis if granted shall expire
thirty (30) days from the date of the attached Order.
I verify that the statements made in this affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18
Pa.C.S.A.~4904, relating to unsworn falsification to authorities.
f-- ,I//P/t~,
Date
} ~~q,ftl? j; khUYJ,
F Petitioner's signature
IFP Generatlons1/23/06
7 of 8
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IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
FAMILY DIVISION
S( I yL-b J)GjY1)'~ I D ,
. Petitioner
v.
Case Number: FD
,
~\r10l)(Ll}JDyr,) ~,
Resp dent
AND NOW,
(u" 9RDER OF COU
this IX!:. ~ay of
, 2006, upon
consideration of the foregoing Petition, it is hereby ORDER that the Petitioner be and
;, h'reby 'r"'" '0 fiI, ."" '"""' th;, "';0" fo< ",&ady ;" th, ,b",,,..,,,M""
case Withu :-ayment of the following:
c(h3jcosts or fees to the Prothonotary
( . Education fees
( ) Mediation fees
( ) Said fees are imposed upon Respondent.
Upon payment, if there is a Non-TANF child support case, Petitioner shall sign a
credit for direct payment, reducing Non-TANF child support arrears in the amount
imposed herein.
Petitioner shall notify the Court immediately of any improvement in
his or her financial circumstances which would permit him or her to pay the
costs incurred herein.
THIS IFP IF GRANTED SHALL EXPIREf1/RTY (30)
f;
ABOVE. t
J.
I FP Generations 1/23106
8 of 8
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SUZEITE DANIELS,
IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY PENNSYLVANIA
st
No. 06- () q CIVIL TERM
vs.
RICHARD MORRIS,
Defendant
'"1;':':1'
r-t-
IN CUSTODY
-:.;,
~~:
PETITION TO ENFORCE FOREIGN JURISDICTION CUSTODY ORDERS'. ~__'
=2
Plaintiff, Suzette Daniels, by and through her counsel, Grace E. D' Alo of
MidPenn Legal Services, states the following:
'-
I. Petitioner, hereinafter referred to as Mother, resides at 319 Euclid Venue,
Glassport, Allegheny County, Pennsylvania.
2. The above Defendant currently resides at 12 Marshall Drive, Apt. 141, Camp Hill,
Cumberland County, P A 17001.
3. Mother and Defendant are the natural parents of:
a. Richard Morris III born October 2, 1996, and;
4. Rebecca Morris, born May 22, 2000.
5. The children have lived Mother for the entire lives in Allegheny County until
Defendant removed them from Mother's custody on May 14, 2006.
6. Mother filed a Complaint in Custody in Allegheny County on May 18, 2006. A
copy of said Complaint is attached to this Petition.
7. Jurisdiction of this custody case is properly before the Allegheny County Court.
8. The Allegheny County Court ordered the children to be returned to Mother with
the assistance of the Sheriffs office. (See attached.)
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9. The Sheriff of Cumberland County should give full faith and credit to the
Allegheny County Court's Order and assist Mother in regaining custody of her
,
children.
Respectfully submitted,
ra E. D' Alo
~ omey for Plaintiff/ Petitioner
dPenn Legal Services
8 Irving Row
Carlisle, P A 17013
~
'-
VERIFICATION
The above-named Plaintiff, Suzette Daniels, verifies that
the statements made in the attached petition for special Relief
are true and correct. plaintiff understands that false
statements herein are made subject to the penalties of 18 Pa.
C.S. 94904, relating to unsworn falsification to authorities.
Date:
5j;3/o~
1 ~1J~
suze~ Dani e 1 s
,
~.
SUZEITE DANIELS,
IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY PENNSYLVANIA
VS.
No. 06-
CIVIL TERM
RICHARD MORRIS, JR.,
Defendant
IN CUSTODY
AFFIDAVIT OF SERVICE
I, Grace D' Ala, do hereby swear that I served Richard Morris, Jr., with a
Petition to Enforce Foreign Jurisdiction Custody Order by having said Petition served by
the Sheriff on May 23, 2006, at the following address:
Richard Morris, Jr.
12 Marshall Drive
Apartment 14 I
Carlisle, P A 17013
I, Grace E. D' Alo, verifY that the statements made in this Affidavit of Service are
true and correct. I understand that false statements herein are made subj ect to the
"
penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities.
Date:
Z;(2-~w
Signature:
~~Dc&v
,
SUZETTE DANlELS,
IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLANDfOUNTY PENNSYLVANIA
4~
No. 06- >' CIviL TERM
vs.
RICHARD MORRIS, JR.,
Defendant
IN CUSTODY
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow, SUZETTE DANIELS, Plaintiff, to proceed in forma pauperis.
I, Grace E. D' Ala, attorney for the party proceeding in forma pauperis, certifY that
I believe the party is unable to pay the costs and that I am providing free legal services to
the party.
Ch: e Alo
Je s a Diamondstone
Grey Biringer
Attorneys for Plaintiff
MidPenn Legal Services
8 Irvine Row
Carlisle, P A 17013
(717) 243-9400
"
THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
FAMILY DIVISION ~
1180 days = \ \ \ Ot.;
Petitioner
Case number:m M5,3-_CQL
~~~~
~~C\C\.
ORDER FOR GenerationsEDUCATION/MEDIATION SEMINAR
And now, to wit, this \ ~"6 day of , 20[X;, it is hereby ordered and decreed
as follows: Both parties in the above captioned m t r shall attend one (1) educational seminar on
Sa3.q'^""-9 \O<!o ,20~at q'OO (am/pm) at the Wiahtman School Communitv Buildina. Any
rercheduling shall be arranged through the Generation office at 412-350-4311 and the education
f"eminar must be completed prior to the scheduled mediation session date.
Respondent
Child or children of the parties are as folloris:q
. Na~ Age '0 Idol III
1. ~'t~Q\.~~\ ~t) ill q~.
2...' ~. . 5 .')1391~
3.
4.
curri reside ~h
.~~
Except as noted below, the above na'med child or children are ordered to attend the children's
interactive group simultaneous with the adult parties attending the adult education seminar. Children
under the age of six (6) years or over 15 years are exempt from attending. .. .. . .....
r.' .- _,,_ ___.,.. -',.~" ,...._:._"' '._-, '.W" ....., -......~--.."....'"--_....':.,._..'<..,-..~:...-._'"~".-.-.~.._.:'~.__.,._"'-"t...""'...'''.''''.~.~.._.:- ~.-',-~"7--:--.,.~.~--'~'"~.".~.~.._-_.....~"~--_.
Payments by the moving party for Generations education seminar and mediation session
must be made at the time of filing.
The movina Dartv (Petitionerl shall be responsible to pav:
1. The Prothonotary filing fee
2. His/her education fee ($40 for the filing party)
3. His/her half of each child's education fee if appropriate ($30 total for each child
between the ages of 6-15 years old = $15/per child per party)
4. His/her mediation fee ($100 for the filing party)
All costs paid into Generations by the Petitioner (filing party) shall be made payable to the Allegheny
County Treasurer in the form of a money order, cashier's, certified. or attorney law firm check AT
THE TIME OF FILING. NO CASH OR PERSONAL CHECKS SHALL BE ACCEPTED BY
GENERATIONS.
6/1/2005 edlmed order
The non-movina party (Respondent) shall be responsible to cav:
1. His/her education fee ($40) for their participation and must be paid to the Generations
office seven days prior to attending the scheduled education seminar.
2. His/her half of each child's education seminar fee, if appropriate ($15 per child
between the ages of 6-15 years old and shall be paid a minimum of seven days prior to attending the
seminar).
3. Hisiher mediation fee ($100) to be paid to the Generations office a minimum of seven
days prior to the scheduled mediation session.
Acceptable forms of payments are money order, cashier's, certified, or attorney law firm check.
Respondent's payments to be made to the Generations office at Generations 440 Ross Street 1"
floor, Pittsburgh, Pa. 15219, Dayable to the Alleahenv CountvTreasurer.
NO CASH OR PERSONAL CHECKS SHALL BE ACCEPTED BY GENERATIONS.
Attendance at the education seminar is mandatary and, upon completion, attendees will receive
a certificate of completion which may be requested by the Court at a later date. Seminars are restricted
tothe parties and children assigned. No third parties shaUbe permittedtoallend.Completion of the
education seminar will be required to proceed to the mediation session.
. The Generations mediation session is scheduled for ":: II 9.. 01 J f} n':JJlt ,20 0("
at I'. n\\ (arrlPOill The mediation session shall be conducted at Generations 4~ss Street 1 51 floor.
Failure to appe)rfor the mediation session will result in forfeiture of fees paid.
The court will not compel a mediation session in a case where either a party or child of either
party has been the subject of domestic violence or child abuse within the past 24 months. A formal
waiver request is available and must be sub milled to the Generations Center no later than seven days
prior to the scheduled mediation session. The submission of a domestic violence waiver does
not excuse any party from particlcation in the education seminar. Parties may arrange to attend
separate classes when a domestic violence waiver has been submitted.
No Darty or child will be permitted to DarticiDate in any of the Proarams unless the fees
are timelv Daid. If vou fail to acpear as Drovlded by this Order. an Order for custodv. partial
custody. or visitation may be entered aaainst vou . Failure to complv with this order mav result in
sanctions f~:Ir contemct or dismissal of the action., .. .
....;:.:,.,.,.::...-
-- ...... ....
_.,.. '_-'_, ;'.;..0...._ __c..C. .;......::... '.;;;'.;~: ",:..: ----,-. __~.:'..~:..~_, ,. ..:. -: ...:....... :.... .:.~.~_.:__;_~.._.~..''-''-.,_.. ,"',. ::"',,"-~ 'O;'~_"~~-'_"'-;'" '~,,- "':-.~'-+ c.~,.-.,'- ."
.,..........'"'....-....,...
.-.---...--,..-.....- --
Security notice:
1. NO THIRD PARTIES. ATTORNEYS OR CHILDREN ARE PERMITTED IN GENERATIONS
DURING A MEDIATION SESSION.
2. ATTORNEYS SHALL ONLY BE PERMITTED IN THE GENERATIONS UNIT FOR
CONCILIATIONS ONLY.
3. CHILDREN WILL NOT BE PERMITTED IN GENERATIONS FOR CONCILIATIONS OR
MEDIATION SESSIONS.
@
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6/1/2005 ed/med order
2
(j
IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
FAMILY DIVISION
5 (,[2<2 +r<[ Dei-lI,hi? j,: ,
Plaintiff
)
)
)
)
)
)
)
No.
vs.
RlchQY1d [i) L' r-f' 1,5 -r~
Defendant .
VERIFICATION
" The adults and/or child(ren) involved in this matter are not now nor have
they ever been involved in a Juvenile Court proceeding or with Children,
Youth and Families (CYF).
o The adults and/or child{ren) involved in this matter are CURRENTL Y
INVOL VED in a Juvenile Court proceeding at No. or with
Children, Youth and Families (CYF). EXPLAIN INVOLVEMENT BELOW.
The Caseworker is whose phone
lumber is .
V The adults and/or child(ren) .involved in this matter have PREVlOUSL Y
been involved in a Juvenile Court proceeding at No. or with
Children, Youth and Families (CYF). EXPLAIN INVOLVEMENT BELOW
The Caseworker was
whose phone number is
The case was closed on
~rm~ -(~)
The involvement in the case is or
was: ~.-}( /gilJ/ I~-'I-!C'(..-c; <(;;c). -;~('::"-~ ~:\.I)CJ""
/
-;r:; ~~': ,~, ~,e"' } Hr-; ~) II.-' ;}~ ,,: /,~ Co ~~ \\,('1-! ~j A \/ }! ,.:>
I I
" ~''', -T I
/', _., /" I .- ':;; "1 L
,~)ds,
I verify that the statements made in this Verification are true and
correct. I understand that false statements herein are made subject to the
penalties of 18 Pa C.S.A. Section 4904 relating to unsworn falsification to
authorities.
Date: ..sj;g Jc> to
o -// f1 ..'
/~vq?,t.v /L-.:;-tt-v-z-r.'c>(/
v Plaintiff
CONFIRMATION OF CUSTODY 1/1/06
Page 1 of 9
//
IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
FAMILY DIVISION
5htr-le.v' ~nlds
/ Plaintiff
v. Case Number: FD
R,cY)c/ r-d '-"ion 1 'SSr. ,
Defendant
EWI-erg-en c /'
COMPLAINT FOR CoN'FIRMATION OF
CUSTODYI
COMPLAINT FOR CUSTODY
Filed on Behalf of:
Name:
~U7ctle Datli eJs
3/9 Euclc/ /lyC
6/ci_C;SOOI-j /b. 150(!.'S
(tj!) Jt/7c) ~/J t/ i:,
Address:
Phone:
CONFIRMATION OF CUSTODY 1/1106
Page 2 of 9
/
NOTICE OF PRESENTATION AND CERTIFICATE OF SERVICE
TO: "R1Ch1!((L~k(n'S~'(.
PLEASE TAKE NOTICE that the within Petition shall be presented to the Pro Se
Motions Judge, Adult Section, Family Division, Court of Common Pleas,
Alleghe,!tounty, Third Floor, Room 3009, 440 Ross Street, Pittsburgh, PA on
the. day of t1."'-o ~ ,2006 at 1:30 P.M.
I hereby certify that a true and correct copy of the within Petition and Notice of
Presentation was served upon Defendant by depositing the ~me in the U.S. Mail,
First Class, postage prepaid on the 1tf day of , fA 12 off . -, 2006
to the address listed below. I
~,;1~
Family Division Pro Se Coordin tor
I verify that the address provided by me and set forth below is the last
known address of the Defendant herein.
/tC.e.
156L-fS-
CONFIRMATION OF CUSTODY 1/1/06
Page 3 019
NOTICE TO DEFEND
You have been sued in court regarding custody of your children. If you fail to appear as
provided by this order, an order for custody, partial custody or visitation may be entered
against you or the court may issue a warrant for your arrest.
YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU
CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE
YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES
TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LAWYER REFERRAL SERVICE
920 CITY COUNTY BUILDING
PITTSBURGH, PA 15219
(412) 261-5555
AMERICANS WITH DISABILITIES ACT OF 1990
The Allegheny County Court of Common Pleas Family Division is required, by law, to comply
with the Americans with Disabilities 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 Family Division. You must attend the scheduled hearing.
ONLY THE PARTIES AND THEIR ATTORNEYS SHALL BE PERMITTED IN THE
GENERATIONS OFFICE ON THE FIRST FLOOR, F AMIL Y COURT FACILITY, 440 ROSS
STREET. CHILDREN WILL NOT BE PERMITTED IN CONCILIATION OR MEDIATION
SESSIONS. NO ATTORNEYS WILL BE PERMITTED IN MEDIATION SESSIONS.
CONFIRMATION OF CUSTODY 1/1/06
Page4of9
~
IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
FAMILY DIVISION
'J
-51 .. x,+( e
, ' I __ II
,) \
\ (iv) I~= /S
Plaintiff
v.
Case Number: FD
", \ \ 1
\'\CIlOiC h
\'10[' r} S Jr.
Defendant
COMPLAINT FOR CONFIRMATION OF CUSTODY/COMPLAINT FOR CUSTODY
1. Plaintiff's name: 5U?Etle I)O'I'{' (S
Residential Address:--)!Cf /'t/ C,;; (l /7 i/ (-'
Plaintiffs Date of Birth 11/7)/1'&7
2. Defendant's name: R l C h a " d L/"1 Dr f'I:> I,.
Residential Address: \1 H . D' k.-J1 r! IV 0 iA.J Add r e ss
" rJ'!C+il~"" Ix,...' n1t.-1.' t
Defendant's Date of Birth "Q 3 ?~ .,f'",.. R" K
G '-1t<-'5'<Jc...-r f}~ )S()l/;>-
3. Plaintiff seeks confirmation of custody of the following child(ren):
Name Present Residence
I 'h.e 3)'1[uc lid /1,'1: (}\QS~
- be /9 tvcl:d
a. The child(ren) (was, e (was not, were not) born out of wedlock. . .~
b. The child(ren) (is, €E?J presently in the custody of ~ I \' VI QI,d ]VIer r I<)(~j
whqse relationship is fa N,r, ,residing at )-k foe 1:: 1<;; ,,), II d, ['",.'
j;; ;I;4l'n>huy riA-It! + Dc!~''f KrJciJ hiS ~d,jre:5- ,"
-.:r:= };:'fJ/(..'llt...) (hi}rhr-...., '. L-/;zJda.., ,Y)()l'PJj ~,,:) fA(';f4,~,t ,-ii (.
GL195C:(j'~-.~-r fb. t'~"r,,~:'!':jf
CONFIRMATION OF CUSTODY 1/1/06
Page 5 of 9
./
c.
During the past five (5) years, the child(ren) ~has:
following persons at the following addresses:
Name Address
<)u2t.He ~)G n .(: Is 3/9"' (~i{0(/ JlLc
have) lived with the
Dates
- J i
,(;;;<' < ~^ ~f' ).'/-.>,')/{'(:
1.._,,0'-_-,/_'<_1 _ __-
d. The mother of the child( ren) is
lives at ':<;/'1 L /1 d
.c- . , /.'
.-J Il;>(.lfc Day;;' f' _<; ,and she currently
vC 6/055':>cI f /"t? /S-c Vs~
e. She is presently { )married, ( )divorced, (b')Single.(check one)
f. The father of the child(ren) is Su/e!lc Ocrr;,'<<:/s and he currently
lives at 111"'('/<' b'.Irc, g,
. ,
'Th....)t/{wOi>J ""'1'"- Ac L.;v',,,,-
g. He is presently (1married, ( )divorced, ( ) single. (check one)
4. The relationship of Plaintiff to the child(ren) is that of J"I '" 1 ), -I. ,7
The Plaintiff currently resides with the following persons:
Name Relationshio
151.<.2" N~ /)Ci.r11C- Is) }lHi OlLie..
, ~
') KId s
5. The relationship of Defendant to the child(ren) is that of f ti. t j, ....r
The Defendant currently resides with the following persons:
Name Re/ationshio
W" -be- ~,~LA~,r-l-~~;.. ~ ~ LAll k _
/~~';plaintiff ( )has ( ~as not participated as a party or witness, or in another capacity, in
, V~ther litigation concerning the custody of the child(ren) in this or another court.
~, the court, term, number and the relationship to this action is: '
OPlaintiff ( )has (~as no information of a custody proceeding concerning this child(ren)
pending in a court of this commonwealth,
If ves, the court, term, number and the relationship to this action is:
CONFIRMATION OF CUSTOOY 1/1/06
Page 6 019
/
Plaintiff x-Jknows c~oes not know of a person, not a party to the proceedings, who
has physical custody of the child(ren) or claims to have custody or visitation rights with
respect to the child{ren).
Ifves, the name and address is.:. ~~4\\~
~~ ',-
7. The best interest and permanent welfare of the child will be served by granting the
relief requested because (set forth facts showing that the granting of the relief requested will be in
the best interest of the child(ren):
~.\ Cc ,""'.
c.1id::
,
0V1\ !
8. Each parent whose parental righ 5 to t chil (ren) has/have not een terminate an
the person who has physical custody of the child(ren) has been named as party to this
action, All other persons, named below, who are known to have or claims a right to
custodyNisitation of the child(ren) have been given notice of the pendency of this
action and the right to intervene:
Name . Addro.. .~~~Qf~~.s.~
$4~~~~~~.
9. Plaintiff requests standing to proceed with this custody action.
WHEREFORE, Plaintiff requests the court grant confirmation of custody of the
children to Plaintiff. In the case of a third party requesting confirmation, Plaintiff
respectfully requests standing to proceed
r n
I! j.(?
'(. ../::5.u,z,,>m )./(?PUV?
. .;/ Plaintiffs Signature
"-//' --. //~/
<; / )'S//{G7
Y /:/""
Date
I verify that the statements made in this Petition are true and correct. I
understand that false statements herein are made subject to the penalties of 18
Pa.C.SA 94904 relating to unsworn falsification to authorities.
" /1 __")
v ~ ) ,'. .. j.
'r- /~J.c.~'';:/C( /,A:':.tc~"c./~-
laintiffs Signature
CONFIRMATION OF CUSTODY 1/1106.
Page 7 of 9
/
IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
FAMILY DIVISION
c9u '2-t +J C.11- ii\!' -t Ls
Plaintiff
v.
_~ I C ~rd-d
Case Number: FD
filo r r 1'5) -r r-,
Defendant
AND NOW, this
day of
ORDER OF COURT
CONFIRMATION OF CUSTODY
presentation he Complaint for Confirmation of Custody, it is hereby ORDE
1. Confj ation of primary custody of the child(ren) (insert names d date of birth):
is granted to Plaintiff (Mot r) (Father) (Grandparent) (Aunt. who resides at the
address set forth in the Petition.
2. The Defendant's right modify this order is pn served.
3. The Generations Program waived.
4.
Plaintiff is responsible for the
ary filing fee for this Petition unless
an In Forma Pauperis petition has been grante9'
.
5. The court will vacate this O'YtJ;f made a re there is an existing custody
,/'
order of court in effect. .1"
lpl:
6. In the case of a thjfd party litigant, standing is here~ granted.
A'"
7. The foregoingJ:hmplaint states a claim upon which re
/ By the Court,
I
CONFIRMATION OF CUSTODY 1/1/06
Page 8 of g
id ()&, -' 2-q 65 u,/
IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
FAMILY DIVISION
s [( '1-.-( fI-('
t1 ~~) ~1s
lainti
No. ~ f) -()(J~9$~-O()I.,
vs.
tic[ltLr{)
)
)
)
)
~(or0t'c;, J f' .l
Defendant )
~ff c '(
~rd,<, r.
CYF IfVV~J11,~o~
5hQ(!
~. <41 ~lY"~
granted to (Mother)
(Father) as follows:
lVA-.
4. The foregoing Complaint states a claim upon which relief may be granted.
"";!::::: . ,.'
5. In the case of a third party litigant, standing is hereby granted;,'t-r : .
B THE COURT: ~i.m,' R9.MTMlRECOf\!I,
MlOHMJ.t.AMB.~EmiONOT~:
0' '~~"
TODY 1/1/06
CONFIRMA
Page 9 of 9
CG
..
C Yf
b o.JuL vJ e"c.ttt ,.:r
..
IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
FAMILY DIVISION
5u ;IC//~
1'(' - -, le-
U .\ 7'\ ,t: --'
Petitioner
v.
Case Number: FD
~) .1 1 \\;1
IUcnGIC \ OfTI.s
Jr. ,
Respondent
E~,
PETITION FOR WAIVER OF
PROTHONOTARY FEES AND
GENERATIONS FEES AND IMPOSING
GENERATIONS FEES ON OPPOSING
PARTY
Filed on Behalf of:
Name '), c' c' DC.7F)/(?/5
Address j/~? EI.-Y/;C A/e
I . >~
6/0:Sl?O/ T h. / SC V
Phone: {II.)) t:2? -// Y ?
I FP Generations 1/23/06
1018
/
NOTICE OF PRESENTATION AND CERTIFICATE OF SERVICE
TO: R,charr/ } . /"/?orns Jr.
PLEASE TAKE NOTICE that the within Petition shall be presented to the Pro Se
Motions Judge, Adult Section, Family Division, Court of Common Pleas,
Allegheny County, Third Floor, Room 3009, 440 Ross Street, Pittsburgh, PA on
the .I-Y'I day of. ,2006 at 1:30 P.M.
/~
I hereby certify that a true and correct copy of the within Petition and Notice of
Presentation was served upon Respondent by depositing the same in the U.S.
Mail, Fi~l ~Iass, postage prepaid on the I 2 *' day Of~,
2006 to t~address listed below.
I~ l '- Il
It~.J?r ~
Family Division Pro Se Coordi tor
I verify that the address provided by me and set forth below is the last
known address of the Respondent herein.
C/D L',ndo. IVJorps
fiD ?> Po clr (fut.
~\O'~?J't_\h jj)Lff
r1....... .
, . IVd0e-.C(
IFP Generations1/23/06
2018
IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
FAMILY DIVISION
',\- ,. \
S,,\ "C \\ ''E, \'f:t ('1 'le I S
Petitioner
v. Case Number: FD
R,cho,J Ir, )\;\OI'J'i~ Jr.,
Respondent
COUNT I
PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS
AND NOW, comes the Petitioner, a party in the above captioned custody
proceeding, who respectfully requests this Honorable Court grant Petitioner leave to
proceed In Forma Pauperis in the above-captioned case and in support thereof, avers
as follows:
1. Petitioner desires to file an action for custody, but is without the funds to
pay the filing fee and/or the Generations fees.
2. Petitioners financial affairs are set forth in a verified statement, a copy of
which is attached to this Petition as Exhibit A.
3. If Petitioner is not permitted to proceed In Forma Pauperis, Petitioner will
be denied due process of law and/or rights under the Constitution of the United States
and the Constitution of the Commonwealth of Pennsylvania.
WHEREFORE, Petitioner prays this Honorable Court grant this Petition and to
allow this action without payment of the required fees.
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COUNT II
PETITION TO WAIVE GENERATIONS' FEES
OR IMPOSE SUCH FEES ON OPPOSING PARTY
AND NOW, comes Petitioner, a party in the above-captioned custody
proceeding, and in support of this motion avers as follows:
1. I am required to pay $ '5 S in education fees and $100 in mediation
fees in connection with this custody action.
2. I ( ..{am ( lam not the moving party in this action.
3. As set forth in the attached Verified Financial Statement, I cannot afford to
pay the education/medication fees.
4. The other party owes support or arrearages in the amount of $3i..2..ln.
WHEREFORE, Petitioner requests the court impose the Education/Mediation
fees upon the other party or waive such fees.
I verify that the statements made in this Petition are true and correct. I
understand that false statements herein are made subject to the penalties of 18
Pa.C.SA ~4904, relating to unworn falsification to authorities.
).lg'D(c
Date
j'''''''''
.jc~;t:k k' ),tfrw;J
i/ Petitioner's signature
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IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
FAMILY DIVISION
5~'2t!!c Dc,,)~( (c:::'
Petitioner
V. Case Number; FD
\('.C}iord 1... ~icr/lS Jr'
Respondent
VERIFIED FINANCIAL STATEMENT
(1:)1 am the Petitioner herein, and because of my financial condition am unable to
pay the-fues and or cost of prosecuting or defending this litigation.
fi) I am the Petitioner herein, and because of my financial condition am unable to
pay the education and/or mediation fees for the Generations Program.
13.\ I am unable to obtain funds from anyone, including my family and associates
to pay\tll'e costs of this litigation.
@:, I represent that the information below relating to my ability to pay the fees and
costs is true and correct:
a.
Name: i'
Address: i
~""---.
b. Emplovment:
Are you presently employed? YES
Employer's name:
Employer's address:
Salary/wages per month:
Type of work:
'>,
@(CircleOne) (SSr)
If you are presently unemployed, state:
Date of last employment: 'f\ la
Salary/wages per month:
Type of work:
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Dividends:
Workman's compensation:
Public Assistance(DPW):
Other:
d. Other contributions to household support ( )wife ( )husband
( )Other:
If the above checked person is employed, provide name of employer:
Salary/wages per month:
Contributions from children:
Other contributions:
e. Property owned:
Cash: tJt) .
Checking/Savings account:
Certificates of deposit:
Real Estate (including home):
Motor vehicle: l~1;>
Cost:
Stocks and/or bonds:
Other:
6Ib ItS
1'4'-L-
Year and Model: awu .,\d;""", (~H"--'
Amount owed: i'u~co
Ni/I.-
f. Debts and obligations:
Mortgage: WON, Rent:
Loans: -
Other: \t,,,,n-tUl '0 J\, CCJl I YlSi I nCl/V1U) en/l pn..y VYl o.-Yl .~
g. Persons dependent upon you for support:
Spouse: (name) i\.'''.... e.
Children: (ifany)~ame: ~~1I1..nd IY)Dm~ TU-..-
R~ \wrrn VV\ {] m <;.
~c\nO.f)r\ ":>",e.
I fro (\'11 ~ ~-E'e..
Other persons: ame: J
Relationship:
c\u. ~Cl\J\,YU. "DQ./Y\..\iJs
ageL
11-
I' '"
1 g mc~hs
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5. I understand that I have a continuing obligation to inform the
Court of improvement in my financial circumstances which would permit me to
pay the costs incurred herein.
6. I understand that this In Forma Pauperis if granted shall expire
thirty (30) days from the date of the attached Order.
I verify that the statements made in this affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18
Pa.C.S.A.g4904, relating to unsworn falsification to authorities.
f-, .j~ //~<y/t~,
Date
t ~/~~,tf? ;; iah~'
// Petitioner's signature
IFP Generalions1/23/06
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/
IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
FAMILY DIVISION
SnyL-b ]()JYU"lI/ L\ ,
, Petitioner
v.
Case Number: FD
,
R\C\1o nrLn1i! rY' S ~,
Resp, dent
UlA QRDER OF COU T
AND NOW, this)~~ay of
, 2006, upon
consideration of the foregoing Petition, it is hereby ORDER
that the Petitioner be and
;, hereby Pr;.ed to me aod porn"" lhi, act;oo toe ,""ody ;0 Ihe ,,,,,,,,.""pOOoOO
case Withu :~ayment of the following:
cpfhcosts or fees to the Prothonotary
{ Education fees
( ) Mediation fees
( ) Said fees are imposed upon Respondent.
Upon payment, if there is a Non-TANF child support case, Petitioner shall sign a
credit for direct payment, reducing Non-TANF child support arrears in the amount
imposed herein.
Petitioner shall notify the Court immediately of any improvement in
his or her financial circumstances which would permit him or her to pay the
costs incurred herein.
THIS IFP IF GRANTED SHALL EXPIR~/RTZ(30~ ,'~,S,FR~~: E DA TE
ABOVE. , ~",
~" 'II
BY H ,OURT:
J.
IFP Generations1/23/06
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c:>
.
SUZETTE DANIELS,
IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND JOUNTY PENNSYLVANIA
J. 91;5
No. 06- CIVIL TEilM
vs.
RICHARD MORRIS, JR.,
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, upon consideration of the attached complaint, this .;t~ day of
"1'J1 ~ ,2006, it is hereby directed that the Cumberland,County Sheriffs Office serve the
above n ed Defendant with the attached Complaint in Custody that was filed in Allegheny
County and registered with the Prothonotary's Office of Cumberland County and the Plaintiffs
Petition to Enforce this Allegheny County Court's Order. The Sheriff of Cumberland County is
also directed to enforce the attached Interim Order of the Comt of Common Pleas of Allegheny
County, directing that the Defendant return Richie Morris III and Rebecca Morris to the care and
custody of the Plaintiff, Suzette Daniels. ~ c1<j......._v ,p,.{/ N 'I.... ..,.. ,.,.........:.1)
10 """,....... .-ir{.... -H... (b....... 1~..:k,
Date:
By the Court,
./1J
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 ASSOCIA nON
32 SOUTH BEDFORD STREET
CARLISLE, P A 17013
(717) 249-3166 OR (800) 990-9108
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individual~ having business before the court,
Pease contact our office. All arrangements must be made at least 72 hours prior to y hearing
or business before the court. You must attend the scheduled c~nference or hearing.
,
!
~
..
SUZETTE DANIELS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
RICHARD MORRIS, JR.,
Defendant
IN CUSTODY
NO. 06-2955 CIVIL TERM
IN RE: PETITION TO ENFORCE FOREIGN JURISDICTION
CUSTODY ORDER
ORDER OF COURT
AND NOW, this 23rd day of May, 2006, upon
consideration of Plaintiff's Petition to Enforce Foreign
Jurisdiction Custody Order and following a hearing at which
the Plaintiff was present and represented by Grace D'Alo,
Esquire, of MidPenn Legal Services, and Defendant was
present and represented himself, the petition is granted to
the extent that the terms of the order of court entered by
the Court of Common Pleas of Allegheny County shall remain
in full force and effect pending further order from that
court, and in accordance with the order the children shall
remain with the Plaintiff at the present time.
Defendant is advised to consult with his counsel
in Allegheny County and, if he deems it appropriate, to
contact the children's services organization in Allegheny
County to advise it of this order.
By the Court,
- ..
LS:g UV Ot ,l.VIi 900Z
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1\(;) V_~I '.., L_,-,~.." ... J._
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....j'-j!.J~.:..... .,:.J:J
yJI .....
Grace D'Alo, Esquire
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
Richard Morris, Jr.
12 Marshall Drive
Apartment 141
Camp Hill, PA 17011
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