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HomeMy WebLinkAbout94-06968 l' '~ ,~ ~~ ~ :. - -- J" ~\ <>-;, I \)" ~ "'" .... v)~ ~-W C'" @ ... ,.. 6j;- 't~ ~ l:l~ ~i ..... ... ~ t; ~ i ~ .... ... d ~... :!; ~ ~ ~ ~:E ... ... ! .03 ~ g j " 0 ~ ~ ..... ' ... ... ... Ul D. ~ Cl ~ ~ > ~ gu f ~ .. ~ D. l:l~1 t; <C W ~ 2: i ~ l('l z J: ... ~ I a:: :t !! ::l % ~ ~f~b w 0 ~ g lI) II w ~ - ~ 06 o " ... 0( z Z % ~~~ . . !!: 8 ! ~ l'-l !!! u ~ ~ 0: '" ~ ~'PCl C) ~ j:!j (J1;~ ^~V l.OI\IOHl.O~d .................... ..-t...I, ..(oO' ,oO~..,..,.,..-..~f"...... . 'Jf'fJ--V '-'Jrt"')fc. ./ .; ...936J..1Y ~~~,!~~..?!.':I,~~~",~~"" ,-'~.J f- l: ~ n., ) _Mltl' tDIUtl". ell,.,.t4I nHI DlfrII""UO:Ji"""l'I1lJl'H"!I'"'' - i 'Y' . . DONALD E. PARRISH, JR., phint.iff . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 94-G%gCIVIL TERM v. : GLORIA PARRISH, Defendant . . . . . . IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claim. set forth in the fOllowing pages, you must take prompt action. You are warned that if you fail to do so, the case will proceed without you and a decree of divorce or annulMent may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselor.s is available in the Office of the Prothonotary at Cumberland county Courthouse, carlisle, Cumberland county, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S F~ES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 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 Court Administrator 4th Floor Cumberland County Courthouse CarliSle, Pennsylvania 17013 (717) 240-6200 vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 94-6968 CIVIL TERM IN DIVORCE DONALD E. PARRISH, JR., Plaintiff GLORIA PARRISH, Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on December 12, 1994. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of a final Decree of Divorce. 4. I have been advised of the availability of marriage counseling, that I may request that the Court require that my spouse and I participate in counseling, and that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I decline to request that the Court require that my ~ spouse and I participate in counseling. 5. I understand that I may lose rights concerning alimony, division of property, lawyers' fees or expenses if I do not claim them before a divorce is granted. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT 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. ~(.L~. DONALD E. PARRISH, ., Plaintiff DATE: 3. ,J/-PS ..... ~ ~ .~ ... - . ;-;.; 2: -~ c ., C'l?' n-, " Q: ~....~ .... ~~ vs. IN THE COURT OF COMMON PLEAS OF ClIMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DONALD E. PARRISH, JR., Plaintiff GLORIA PARRISH, Defendant 94-6968 CIVIL TERM IN DIVORCE !FFIDAVIT OF CONSENT 1. A Complaint in Divorce under section 3301(c) ot the Divorce Code was filed on December 12, 1994. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the tiling of the Complaint. 3. I consent to the entry of a final Decree of Divorce. 4. I have been advised of the availability of marriage counseling, that I may request that the Court require that my spouse and I participate in cOllnseling, and that the Court maintains a list of marriage counselors in the prothonotary's Ottice, which list is available to me upon request. Being so advised, I decline to request that the Court require that my spouse and I participate in counseling. 5. I understand that I Olay lObe rights concerning alimony, division of property, lawyers' fees or expenses if I do not claim them before a divorce is granted. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT 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: V'l ~ ," = ~." ,.. ;7- M '::3 '" d' >- ., ,C "'= "7r (--4' - tt c. : M u -..1" \ . - ~ --. ~ J :l- \'-1 0 0 " I 1'1\ '" C_l - 11- \i) 8) ...... it i4 -4.,. ~ cJ ~I ~~ ~ ~~~ i~B~ i~~~ ~ El'~ ~ ~ ti(il;8 _"u..~o.. OIUIIlt()I D:) n.':'~"".('U"'" fllU ~1111U"'" ~..... ...... ~.j l: 6f~ ill< Po ~ I I ~ ~~ . ~ ~ Po ~ ~ I 9 ~ l! ~ ... III 0. g Z ' '" ~ ~ ..::E :> . " .il ~ ~ z ~ v c _ z U lil ti .... '" 0( II G J Iii ~ oj II 0 . '" " ~ ~ ~ :( :( ~ Z 0. .. C ' ~ ~ 1: ~ II Z ~ W 0 ~ J - ~ 0 ~ l:: 0( z U ~ ~ ~~ ~~ 8~ ~ tV--- DF 1 !J 1994 CONALtJ E. PARRISH, JR., Plaintift : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 94- G'Ib fr CIVIL TERM CUSTODY v. GLORIA PARRISH, Defendant . . . . . . ORDER OF COURT AND NOW, this ) ) tl( day ot ~\,L. (t .1'--l---t'.,"''---, 1994, the attached stipuleotion and Agreement is hereby made an Order ot Court and all prior Orders on this matter are hereby vacated. BY THE COURT, /~t 'r'\ re (~fvvl/ r- J. v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 94- (/) (,15 CIVIL TERM IN CUSTODY DONALD E. PARRISH, JR., Plaintitf GLORIA PARRISH, Defendant . . : CUSTOD~ STIPULATION AND AGREEMENT THIS AGREEMENT AND STIPULATION entered into the day and year hereinafter set forth, by and between Gloria Parrish, (hereinatter referred to as "Mother") and Donald E. Parrish, Jr., (hereinafter referred to as "Father"). WHEREAS, the parties are the natural parents of carissa L. Parrish, born December 6, 1984 (hereinafter the "child"): and WHEREAS, the parties are presently separated and living in separate residences; and WHEREAS, the parties wish to enter into an agreement relative to custody and partial custody of the child; and NOW, THEREFORE, in consideration of the mutual covenants, promises and agreements as hereinafter set forth, the parties agree as follows: 1. ,The parties will have shared or joint legal custody of the child. 2. Father shall have primary physical custOdy of the child. J. Mother shall have periods of temporary or partial custody as the parties may agree with the understanding that the child's desires will be taken into consideration relative to the periods of physical custody that the child spends with Mother. 4. The partie. will keep each other advised immediately in the event ot serious illness or medical emergency concerning the child and shall turther take any necessary steps to ensure that the health and well being ot the child is protected. During such illness or medical emergency, both parties shall have the right to visit the child as otten as he or she desires consistent with the proper medical care of the child. 5. Neither parent shall do anything which may estrange the child trom the other party, or injure the opinion ot the child as to the other party, or which may hamper the tree and natural development ot the child's love or affection for the other party. 6. Any modification or waiver of any of the provisions of this Agreement shall be effective only it made in writing and only if executed with the same tormality as this stipulation and Agreement. 7. The parties desire that this stipulation and Agreement be made an Order of Court to the Court of Common Pleas of CUII1berland County, and further acknowledge that the Court of Common Pleas ot Cumberland County does, in tact, have jurisdiction over the issue of custody of the parties' minor child and shall retain such jurisdiction should circumstances chanqe and either party desire or require modification of said Order.