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Home My WebLink About06-5282 TERESA D. MERCER, Plaintiff = IN THE COURT OF COMMON PLEAS OF = CUMBERLAND COUNTY, PENNSYLVANIA . . v. = CIVIL ACTION - LAW = NO. 2008 - S'UJ.cIVIL TERM (") ~ ;<;: "'TIn' [l~i f.~ SHAWN M. HILL and SHANNA LEE GUTSHALL, Defendants = IN CUSTODY COMPLAINT FOR CUSTODY NOW comes the plaintiff, TERESA D. MERCER, by her attorney, Harold S. Irwin, III, Esquire, and presents the following complaint for custody, representing as follows: 1. The plaintiff is TERESA D. MERCER, an adult individual residing at 420 Nealy Road, Newville, Cumberland County, Pennsylvania 17241. Plaintiff is the maternal grandmother of the minor child who is the subject of this action. 2. Defendant SHAWN M. HILL is an adult individual residing at 465 Gutshall Road, Boiling Springs, Cumberland County, Pennsylvania 17007, and defendant SHANNA LEE GUTSHALL is an adult individual residing at Walsenburg, Colorado. 3. The defendants are the natural parents of the child who is the subject of this action, namely, KODY DANIEL HILL, born November 9,2005. 4. The defendants were not married at the birth of the child, but resided together until the end of April, 2006, at which time defendant Gutshall moved in with her mother, the plaintiff. 5. On May 24, 2006, defendant Hill signed over his parental rights to defendant Gutshall by notarized statement incorporated herein and attached hereto as Exhibit "A". 6. Defendant Gutshall moved with the child to Glen Rock, Pennsylvania in June, 2006 and on or about July 23, 2006 moved with the child to Colorado. ....., = <= "" (/) r-r'1 CJ I OJ o " :r rn:n r -om c['y "S;~ ('SIT! ~I ....> :n -< ..,., :J:.: r' '" o..D , 7. On August 24,2006, defendant Gutshall returned the child to Pennsylvania to live with the plaintiff and on that date executed a document giving legal custody to the plaintiff and purporting to name plaintiff and F. Elise Wckard (the child's paternal aunt) as the child's legal guardian. A copy of this document is incorporated herein and attached hereto as Exhibit "B". Defendant Gutshall then returned to Colorado. 8. 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. 9. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. 10. 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. 11. The best interests and permanent welfare of the child require that the parties have joint legal custody of the child, that the plaintiff have primary physical custody and that defendants have periods of supervised visitation as may be mutually agreed. WHEREFORE, the plaintiffs request that the court enter an order providing for the legal and physical custody of the child as aforesaid. September 7,2006 HAROLD S. IRWIN, III Attorney for Plaintiff 64 South Pitt Street Carlisle, Pennsylvania 17013-3220 (717) 243-6090 Supreme Court 1.0. No. 29920 v VERIFICATION I do hereby verify that the facts set forth 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. September 7,2006 it.~1.kppj .' EXHIBIT ..A.. " . Commonwealth of Pennsylvania ) )SS: County of Cumberland ) Before me, the undersigned notary public, this day, personally, appeared Shawn M. Hill to me known, who being duly sworn according to law, deposes the following: Hereby signs over all parental rights to Shanna Lee Gutshall for Kody Daniel to include all of the child's medical, physical, and emotional 1 e' Shawn M. Hill j~~~~1M2J2JJ Shanna Lee Gutshall Subscribed and sworn to before me this 24 day of May, 2006. COMMONWEAlTH OF PENNSYlVANIA NOTARIAL SEAL LESLIE MANUEL. NOTARY PUBLIC CITY OF CARUME, CUMBERLAND COUNTY MY COMMISSION EXPIRES JULY 23. 2008 . , ,. . . EXHIBIT "B" .' J I, ShalUla Lee Gutshall, appoint my mother Teresa D. Mercer and/or my aunt F. Elise Wickard, as Power of Attorney and Legal Guardians for my son Kody Daniel Hill. 1 authorize my mother and/or my aunt to make any and all decisions for my minor child. This includes but not limited to medical treatment, prepare applications, provide information, and perform any other act reasonably requested by any government or its agencies in connection with governmental benefits. orA I. L . \J r tl'\ (}, Y \ lAm G~ivi'{\~ L,,,,:)V' Iv '" v' . -\I:J MY \\!\\l-\ne.v \~XQS'(A O. ~~( ~ --.....~ \N ~hkWlJLfJ2:JJ ,SujfbO 0 L Shanna Lee Gutshall {/;f!!fsl::t11g-~ d (~.:..ltld) F. Elise Wickard 0 ....., ~ = 0 ~ :;';-;' C'j -n - "::'" en }-J ~ " U) =I' ".., ?.J ~7 nl:TI t r- 1f:- I -nm . :r:)CJ e \) ex:> C:;(S ~ CJ ?5I~ ~ ".0 '.. f5m - -- ~- .;c- ~ :,< .. -.~ ~ C) .:~ f'oJ ;>> -< .0 co -< "-> .t. " ~ l ::0 -- ~ / i ~ . TERESA D. MERCER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 06-5282 CIVIL ACTION LAW SHA WN M. HILL AND SHANNA LEE GUTSHALL IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Friday, September 15, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, October 19, 2006 , the conciliator, at 10:30 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. All children age five or older may also be present at the conference. 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 ReHef orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: Isl Hubert X Gilroy, Esq. Custody Conciliator f*L 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 HA VE 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 J;"7?~ ,~ ,~ ~,w:'r Mp ~t1-6;'(; @ ~ ~ ~~;t.. '7r?'b"~ ~ fr:' :z ~- 46.7 ~ '%'-6/-1> I VlNV!9^SNN3d )J.Nni..o :.l~.:'1j'l\.r::lHI^,nl"\ ->-...\"....r 11 ......1 J S :21 Wd 61 d3S 900l ^b'VIO~j9~.lOcd 3H.1 :10 :J \.)i.:::1Q-{]31I:l - THERESA MERCER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LA W IN CUSTODY SHAWN M. HILL and SHANNA LEE GUTSHALL, Defendants NO. 06-5282 PRAECIPE TO ENTER APPEARANCE To the Prothonotary: Please enter the appearance of the Family Law Clinic on behalf of Shawn Hill, a Defendant in the above captioned matter. Date October 23.2006 .. Cf-u1flLtl ~Y\d Charece Collins Certified Legal Intern for Defendant f!~J f!w~ Meg I esmeyer Supervising Attorney F AMIL Y LA W CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 Fax: (717) 243-3639 THERESA MERCER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION-LAW IN CUSTODY SHA WN HILL and SHANNA LEE GUTSHALL, Defendants : NO. 06 - 5282 CERTIFICATE OF SERVICE I, Charece Collins, Certified Legal Intern, Family Law Clinic, hereby certify that I am serving a true and correct copy of my Praecipe to Enter Appearance on Harold Irwin, Esquire, of Irwin Law Office, counsel for Plaintiff, whose office is located at 64 South Pitt Street, Carlisle, Cumberland County, Pennsylvania, by depositing a copy of the same this date in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid to said address. 'O-2~-DtL/ Date ~ c.h~/1Lcx. C~VY\i~ Charece Collins Certified Legal Intern ~~A fua~ Meg iesmeyer Supervising Attorney F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 Fax: (717) 243-3639 !'--' = = a.... <::) C- --l N W ~'... o -n ~-n n'F ~....)m ~h C;J ~){~ ,-1 -(I ";;...-:- -Y1 ,-:;C') {)I-n _-:---1 ?n -< -0 C".) l'j 0'\ to-) = = ~ q;I") c:Q...; ~ ~ ""0.) ::r .+>..) r~.. f'-:> U', -- THERESA MERCER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LA W : IN CUSTODY SHA WN HILL and SHANNA LEE GUTSHALL, Defendants : NO. 06-5282 PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Shawn Hill, Defendant, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Respectfully submitted, Date October 23. 2006 c~U- ~Q..~ Charece Collins Certified Legal Intern ~~d ~J~~ ROB T E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717-243-2968 717-243-3639 - THERESA MERCER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION-LAW IN CUSTODY SHA WN HILL and SHANNA LEE GUTSHALL, Defendants : NO. 06 - 5282 CERTIFICATE OF SERVICE I, Charece Collins, Certified Legal Intern, Family Law Clinic, hereby certify that I am serving a true and correct copy of my Praecipe to Proceed In Forma Pauperis on Harold Irwin, Esquire, of Irwin Law Office, counsel for Plaintiff, whose office is located at 64 South Pitt Street, Carlisle, Cumberland County, Pennsylvania, by depositing a copy ofthe same this date in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid to said address. I 0 - 2 ~- 0/.0 Date .... C~ CstQ~ Charece Collins Certified Legal Intern fi~ ~Pl Megan iesrneyer ,~. Supervising Attorney F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 Fax: (717) 243-3639 o ~, ~Y' -:> 'c::::> ~ o ("'J _-I ~ 1:::n pIC:: -otI:; 4:1"-, .:~).<:? ::~i~\ ':::-..\ '~ ''''':;' -0 "> -:; ~. '" cr. . THERESA MERCER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY SHAWN M. HILL and SHANNA LEE GUTSHALL, Defendants : NO. 06-5282 Now comes Shawn M. Hill, a Defendant in the above captioned action, and files the following Answer and Counterclaim in Custody. COUNT I. ANSWER 1. Admitted. 2. Denied. Defendant Shawn M. Hill resides at 1117 Trindle Rd., Carlisle, P A 17013. Defendant Shawn M. Hill is without sufficient knowledge to either admit or deny Shanna Lee Gutshall's address. 3. Admitted. 4. Admitted in part and denied in part. By way of further answer, Defendant Shawn M. Hill admits that he was not married to mother at the birth of the child, but denies the date of April, 2006 as the date when they stopped living together. Defendants resided together until May, 2006. 5. Admitted in part and denied in part. By way of further answer, Defendant Shawn M. Hill admits that he signed the document attached to Plaintiffs complaint for custody as Exhibit A. Defendant Shawn M. Hill denies that the document attached to Plaintiffs complaint for custody as Exhibit A has any legal force or effect. 6. Defendant Shawn M. Hill is without sufficient knowledge to either admit or deny the allegation. 7. Defendant Shawn M. Hill is without sufficient knowledge to either admit or deny the allegation. 8. Admitted. 9. Admitted. 10. Admitted. 11. Denied. By way of further answer, the best interests and permanent welfare ofthe child require that Defendant Shawn M. Hill have primary legal and physical custody and that Plaintiff has periods of supervised visitation as may be mutually agreed. Plaintiff has no basis on which to suggest supervised visitation for Defendant Shawn M. Hill. COUNT II. COUNTERCLAIM IN CUSTODY 12. The answers to paragraphs 1 - 11 are incorporated by reference. 13. Defendant Shawn M. Hill seeks primary custody of the following child: Name Present Residence Age Kody Hill 420 Nealy Rd. Newville, PAl 7241 DOB: 11/09/05, 10 months The child was born out of wedlock. The child is presently in the custody of Theresa Mercer, who resides at 420 Nealv Rd. Newville. P A 17241. Theresa Mercer has no legal guardianship or custody over the child. During the past five years the child has resided with the following persons at the following addresses: Persons Address Dates Shanna Lee Gutshall & Shawn Hill 564 Gutchall Rd. Apt. A Nov. '05 - May '06 Boiling Springs, P A 17007 Shanna Lee Gutshall & Theresa Mercer 420 Nealy Rd. Newville PA, 17421 June '06- Aug. '06 Shanna Lee Gutshall Colorado August '06 Theresa Mercer 420 Nealy Rd. Newville, PA 17421 Aug. ' 06 - present The mother of the child is Shanna Lee Gutshall She is single. The father of the child is Shawn Michael Hill He is single. 14. The relationship of Defendant Shawn M. Hill to the child is that of father. Defendant Shawn M. Hill currently resides with the following persons: Name Relationship Ron Hill Father 15. The relationship of Plaintiff to the child is that of grandmother. Plaintiff currently resides with the following persons: Name Relationship Unknown 16. Defendant Shawn M. Hill has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Defendant Shawn M. Hill has no information of a custody proceeding concerning the children pending in a court of this Commonwealth, or any other state. Defendant Shawn M. Hill does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 17. The best interest and permanent welfare of the child will be served by granting the relief requested because: a. Defendant Shawn M. Hill is able to provide the child with a stable home and environment with adequate mo!al, emotional, and physical surroundings as required to meet the child's needs; b. Defendant Shawn M. Hill will permit contact between Plaintiff, her family, and the child; c. Defendant Shawn M. Hill is willing to accept custody of the child. d. In August, without notice to Father, Mother left the child with Maternal Grandmother and moved to Colorado. When Father learned of this, he tried to take the child from Maternal Grandmother, and she refused to give the child to him. e. The child's mother left Plaintiff a note saying that "she would never see her again." Child's mother's current location is unknown. f. Plaintiff has no legal custody or guardianship over the child, and is holding the child from the biological father against his will. g. Plaintiff does not meet the standards for a grandparent to obtain custody pursuant to 23 Pa.C.S. g5313(b). 18. Each parent whose parental rights to the children have not been terminated and the person who has physical custody to the child have been named as parties to this action. WHEREFORE, Defendant Shawn M. Hill requests the court grant him primary legal custody and primary physical custody of the child. Respectfully submitted, Date: IO-b23-0u, ~ ('~~) CHARECE COLLINS Certified Legal Intern ~f.~ THOMAS M. PLACE ROBERT E. RAINS LUCY JOHNSTON- WALSH ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys THE F AMIL Y LA W CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 VERIFICATION I verify that 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. ~ 4904 relating to unsworn falsification to authorities. Date: 10 ~ 23 - Ob ~Jl4 SHAWN MICHAEL HILL THERESA MERCER, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION-LAW : IN CUSTODY SHA WN HILL and SHANNA LEE GUTSHALL, Defendants : NO. 06 - 5282 CERTIFICATE OF SERVICE I, Charece Collins, Certified Legal Intern, Family Law Clinic, hereby certify that I am serving a true and correct copy of my Answer and Counterclaim in Custody on Harold Irwin, Esquire, of Irwin Law Office, counsel for Plaintiff, whose office is located at 64 South Pitt Street, Carlisle, Cumberland County, Pennsylvania, by depositing a copy ofthe same this date in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid to said address. 10 - 2.:' - OLD Date C.f\Q\j\.e.u C~tv~ Charece Collins Certified Legal Intern !~:.~~ Supervising Attorney F AMIL Y LA W CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 Fax: (717) 243-3639 -... ~ i-' IT () r; r.......') e-"'.l G::;) 0-' o C) -I N W o ..1 .-1 I" f11p \Jill -, 1 I:."J ~~~; .... -,.., 2~~ --1 ~-o -< -0 ~ N N 0\ From: IRWIN LAW OFF1CE 717 243 9200 11/09/2006 11:00 #310 P.OOS/007 v. I IN THI COURT 0' COli liON I'LIIA. O' I CU..IRLAND COUNTY, P...rtLVANJA I . OML ACTION - LAW I NO. Hoe-" CML T." I TII.uA D. -.011" ....ntltl -.AWN M. HILL .... 8HANNA LU GU"NHALL. a....d.... . . I IN CUaTODY aTIPULATION AND AGIIIMIKI THIS STIPULATION AND AGREEMENT entered into thiS I~~ay ot November, 2006, by and between TeRESA D. MERceR and SHAWN M. HILL. NOW THIS AGREEMENT WITNESSETH THAT: WHEREAS, 1he plaintiff, Teresa D. Mercer, is the maternal grandmother (hereinafter Grandmother) and defendant, Shawn M. Hill, is the natural father (hereinafter Father) of KODY DANIEL HIL.L., bom November 9,2005; and WHEREAS, the Grandmother filed a custody complaint seeking primary physical custody of the child and, pursuant thereto, the parties held a conciliation conference on November 8, 2008; and WHEREAS, the Grandmother and Father wish to enter into an agreement relative to the custody, visitation and partial custody of the child. without purporting to establish or to take away any rights of the Mother 01 the child, Shanna Lee Gutshall, and without prejudice to Mother's rights to appear and assert any rights.. NOW, THERI!FOR!, in Goneideration of the mutual covenants, promises and agreement8 as hereinafter set forth and intending to be legally bound, thA Grandmother and the Father agree as follows: From: IRWIN LAW OFFICE 717 243 9200 11/09/2006 11:01 #310 P.004/007 ,~,/ " The Grandmother and Father shall have joint legal custody of the child. Joint legal custody means the Grandmother and the Father shall jointly share the right of control of the child and shall share in making deCisions of importance in the lite at the childl including educational. m~dlcal and religious doclslonG. Both shoJI be entitlod to equal &00038 to the child's 8Ohoof, medical, dental and other important records. Notwithstanding the foregoing. non-major decisions involving the child's day-to-day nving shall be made by the party then having physical custody, consistent with the other provisions of this Agreement and Order and the best Interests of the child. 2. The Grandmother shall have primary physical oustodyof the child from the date of thi8 agreement until December 15. 2008. subject to Father's periods of partial custody of the child as follows: A. On Thursday, November 9,2006, the child's birthday, from 5:30 p.m. until 7;00 p.m.; B. On Wednesday, November 15, 2006, from 5:00 p.m. until 7:00 p.m. (Grandmother will provide the transportation to Father's house at 5:00 p.m. and Father will return the child to Grandmother's house at 7:00 p.m.) C. On Saturday November 18, 2006, from 11:00 a.m. until Sunday, November 19. 2006, at 5:00 p.m.: O. For the ThanksgMng Holiday, from Wednesday, November 22,2006, at 5:00 p.m. until ThankGgiving Day, November 23, 2008, at 4:00 p.m.; E. On Wednesday, November 29, 2006, from 5:00 p.m. until 7:00 p.m.; F. On Saturday, December 2,2006, 1rom 11:00 a.m. until Sunday, December 3,2006, at 4:00 p.m.: G Every Wednesday, from 5:00 p.m. until 7:00 p,m.; and H. Such other times as the parties may mutually ayretJ, with 24 hour8 notice. From: IRWIN LAW OFFICE 717 243 9200 11/09/2006 11:01 #310 P.005/007 3. Beginning on December 15, 2006, the Father shall have primary physical custody of the child, subject to Grandmother's periods of partial custody of the child as follows: A. Every other weekend, beginning on Friday. December 22, 2006, at 5:00 p.m. until Sunday, at 5:00 p.m.; B. For the Christmas holiday, from December 25, at 2:00 p.m. until December 26, at 11 :00 a.m.; C. On Thanksgiving Cay, from 10:00 a.m. until 6:00 p.m. on even numbered years (the Father will have the child on those Thanksgiving times in odd numbered years); O. On Eaeiter Sunday from 2:00 p.m. untll 6:00 p.m.; and E. Suoh other times as the parties may mutually agree, with 24 hours notice. 4. Father will always have the child on Father's Day from the day before at 5:00 p.m. until Sunday at 5:00 p.m.. Grandmother will always have the chUd on Mothers Day during Lhe ~mti time periods. 5. Both parties shall have reasonable telephone contact with the child while the child is in the otherts custody. 6. Unless otherwise agreed. Father will provide transportation fer his partial custody times and Grandmother will provide transporta1ion for her partial custody times. 7. Both the Father and Grandmother understand and agree that the child presently has a regular schedule, getting up at 6:00 a.m., napping between 1 :00 p.m. and 3:00 p.m. and going to bed for the night at 8:00 p.m. Both will make every effort to follow this schedule and to communicate and cooperate regarding the diet, medical concerns and other activities of the child. 8. Both Father and Grandmother agree that they wUl not permit anyone In the household to use controlled substances or to abuse alcohol during any time that the child is In their custody. From: IRWIN LAW OFFICE 717 243 8200 11/08/2006 11:02 #310 P.006/007 -- 9. Father and Grandmother agree to keep each other advised immediately relative to any emergencies conceming the ohlld and shall further take any necessary steps to insure that the health, welfare and well being of the ohild is protected. 10. ...EXGsJlt as 8tR.~~1i18 iRsisata9 iR tRie 18feeM!At. tJ,lther the Father nor the Grandmother or other members of their respective households shall do anything that may estrange the child from "the other or hinder the natural development of the child's love or affection for the other party. ~ C~ ~ 11. Tho Father and the Grandmother may mutually agree to modify these provisions from time to time; however. no modification or waiver of any of the provisions of this agreement shall be legally effective unless made in writing and only if executed with the same fonnality of this agreement. 12. The parties agree that in making this agreement there has been no fraud, concealment, overreaching. coercion or other unfair dealing on the part of the other. Father has had the assistance of counsel from the FamHy Law Clinic and Grandmother has been represented by Harold S. Irwin, III, Esquire. 13. The parties desire that this agreement be made an order of Court through the Court of Common Pleas of Cumberland County. and further acknowledge that the Court of Common Pleas of Cumberland County has jurisdiction over the issue of custody of the ohild and shall retain such jurisdiction should circumstances change and either party desire further or require further modification of said Order, cl?nsisfelff ",i~ ~ tJ"~..,,, d/l'M C...st...f ;J;r-is,,/,i:-lih) ~~ a.v.' &(f,rCI.W/#!"i- Ae.+. CG IN WITNESS WHEREOF, the partiea hereto, intending to be legally bound by the terms hereof. set c;.. forth thejr hands and seals the day and year herein set forth. WITNESSETH: (SEAL) (SEAL) t~ .. .: . . . ..'\:: .;-:t. 'iI , .~ . t .,' . '. ,-" .." " , .. ,j . 'I' ~ ;, ", " ... 'I ~ ... . '-:, 'I C ...~. ~ (~ ':::~ f';;"'''t-'' () -n ...".. ....~1._ c:,;; ~...: -..! -0 :1-': N C,) L-) " 'r " I l rrOIIl.HmJI'I um UrrJt.,.c I III L:4J :j:LUU III U~I L:UUb 11: CO #.3; 0 P. 002/Ci07 ....' " tv NOV J' ZCJD6 ptt i HAROLD" IRWIN, III, UQ. AYYORN~IDNO.~O NSOUTH Pin' I'!'UaT CAlUdIU PA t701a (717) t..... An'OIINW 11011 PLAlJrftIl' TII~ D. ....C.R, P'a'JltIff .. : IN TN. GOURT OF COMMON PLEAa 0' J CU.8IRLAND COUNTY. 'INNrtLVAtlIA Y. I CML AMION . LAW I NO. 2OOI-12U CNIL TIRM I I I IN CUITODY .HAWN M. HILL ..wi SHANNA 1.8. ClUftHALL, D........ ORaI!R OF COURT :tt, NOW this 2,B day of November, 2008. upon pl'888ntation and consideration of the attaohed Stipulation and Agreement and upon agreement of the parties, it is hereby ordered and decreed that the attached agreement is made an Order of Court. ((-J-q-O~ ~ ~ JrI6 J VIN\fI\1A.SNN3d }JNnO~} C1t.r'[!11:{j8V'ln~ Btt : I Wd 6, ^ON 900l Ai:N10NOHl08d 3Hl :lO 3Q1.i~O-031\;t