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Home My WebLink About02-3893 STEPHANIE JANE RANFT and ERROL THEODORE RANFT, PLAINTIFFS vs. CARRIE LYNN DOHERTY, STEPHEN SHAWN MORGAN and SANDRA JANE BASEHORE, DEFENDANTS : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA : NO. CIVIL TERM : CIVIL ACTION - LAW : ACTION FOR CUSTODY NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the Plaintiffs. You may lose money or property or other rights important to you, YOU SHOULD TAKE TIDS 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 Association 2 Liberty Avenue Carlisle PA 17013 (717) 249-3166 1-800-990-9108 STEPHANIE JANE RANFT and ERROL THEODORE RANFT, PLAINTIFFS VS. CARRIE LYNN DOHERTY, STEPHEN SHAWN MORGAN and SANDRA JANE BASEHORE, DEFENDANTS : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYL VANIA : NO_ CIVIL TERM : CIVIL ACTION - LAW : ACTION FOR CUSTODY COMPLAINT FOR CUSTODY AND NOW, come the Plaintiffs, STEPHANIE JANE RANFT and ERROL THEODORE RANFT, by and through their counsel, Susan Kay Candiello, Esquire, of the Law Firm of Susan Kay Candiello, P.C., and file this Complaint for Custody upon a cause of action of which the following is a statement: I. The Plaintiffs are STEPHANIE JANE RANFT and ERROL THEODORE RANFT (hereinafter sometimes known as "Aunt and Uncle") who currently reside at 212 North King Street, Leesburg, Virginia, 20176, 2, Defendant one is CARRIE LYNN DOHERTY (hereinafter sometimes known as "Mother") who currently resides at 504 Fourth Street, Apartment B, New Cwnberland, Cwnberland County, Pennsylvania, 17070. 3. Defendant two is STEPHEN SHAWN MORGAN (hereinafter sometimes known as "Father") who currently resides at 27 West Coover Street, Apartment B, Mechanicsburg, Cwnberland County, Pennsylvania, 17055, 4. Defendant three is SANDRA JANE BASEHORE (hereinafter sometimes known as "Grandmother") who currently resides at 134 Lancaster Boulevard, Mechanicsburg, Cwnberland County, Pennsylvania, 17055. 5, Plaintiffs presently seek Full Legal and Primary Physical Custody of the following child: Name Present Residence Date of Birth ALLISON MARIE MORGAN 134 Lancaster Blvd. Mechanicsburg, P A 10/31/94 6. The child was born out of wedlock. 7. The child is presently in the Primary Physical custody of Grandmother who resides at 134 Lancaster Boulevard, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 8. During the past five (5) years the child has resided with the following persons at the following addresses: Name(s) Address !!!!g Grandmother 134 Lancaster Blvd. Mechanicsburg P A October 31, 1994 to Present 9, The mother of the child is Defendant Carrie Lynn Doherty, who currently resides at 504 Fourth Street, Apartment B., New Cumberland, Cumberland County, Pennsylvania, 17070, 10. Defendant Carrie Lynn Doherty was never married to Defendant Stephen Shawn Morgan. She has primarily resided with Defendant Sandra Jane Basehore since the last custody order was entered on November 29,1994, 11. The father of the child is Defendant Stephen Shawn Morgan, who currently resides at 27 West Coover Street, Apartment B, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 12, Defendant Sandra Jane Basehore is the natural maternal grandmother of the child, who currently resides at 134 Lancaster Boulevard, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 13, The relationship of Defendant Carrie Lynn Doherty to the child is that of natural mother. Defendant Carrie Lynn Doherty currently does not reside with any additional persons. 14. The relationship of Defendant Stephen Shawn Morgan to the child is that of natural father. Defendant Stephen Shawn Morgan currently does not reside with any additional persons, 15. The relationship of Defendant Sandra Jane Basehore to the child is that of natural maternal grandmother. Defendant Sandra Jane Basehore currently does not reside with any additional persons, 16, The relationship of Plaintiffs to the child is that of natural aunt and uncle. Plaintiffs currently do not reside with any other individuals 17, Defendants have participated as parties in a prior custody agreement concerning the custody of the child in this court. The court, term and number, and its relationship to this action are as follows: the court was Cumberland County, the docket number is 94-6698 Civil Term, the result was a custody order dated November 29,1994, a copy of which is attached hereto and made a part hereof as Exhibit "A", 18. Plaintiffs and Defendants have no information of a custody proceeding concerning the child pending in a court of this Commonwealth at this time. 19. Plaintiffs and Defendants do 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, 20, The best interests and permanent welfare of the child will be served by granting the relief requested because: A. Mother and Father are unable to maintain legal and physical custody of the child; B, Grandmother is unable to provide the time necessary for the child to be involved in activities and be in the home for the child; C. The Plaintiffs and Defendants have great love and concern for this child; D, Aunt and Uncle are married and own their own home in a quiet average middle class neighborhood. Uncle has stable employment with full benefits, Aunt is a stay-at-home wife and mother. Aunt and Uncle have no other children of their own; E, The child has visited with Aunt and Uncle for several summers and throughout the past few years. The child has friends in their neighborhood and would like to live with Aunt and Uncle; F. Aunt and Uncle have great love and concern for the child as the child does for them; G, Aunt and Uncle have the ability to provide the child with a stable home, a mother who is always at home, participation in extracurricular activities, and many other benefits the child does not have available to her at her present residence; H, As a direct result of the Plaintiffs and Defendants' great love and concern for the child, Plaintiffs and Defendants have made the joint decision that Aunt and Uncle should be the primary parents for the child; I. The child desires Aunt and Uncle to be her primary parents, 21. Each parent and grandparent whose parental and custodial rights to the child have not been terminated have been named as parties to this action. WHEREFORE, Plaintiffs, STEPHANIE JANE RANFT and ERROL THEODORE RANFT, request this Honorable Court grant Plaintiffs, STEPHANIE JANE RANFT and ERROL THEODORE RANFT, Full Legal Custody and Primary Physical Custody, and Defendants, CARRIE LYNN DOHERTY, STEPHEN SHAWN MORGAN and SANDRA JANE BASEHORE, Partial Physical Custody of the minor child, ALLISON MARIE MORGAN, Respectfully submitted, LAW FIRM OF SUSAN KAY CANDIELLO, P.C. Dated: August J3.., 2002 Susan Kay Candi Esquire Counsel for Pial tiffs PA I.D, # 64998 5021 East Trindle Road Suite 100 Mechanicsburg P A 17050 (717) 796-1930 Aug 13 02 12:08p AUG 13 G2 11.iOa SKC La,. 703-777-2263 717-796-1933 p.4 P:4 VERI FrCATlON The undenigned heteby verifies that die raeL~ averred in the: f_going doeUnlCnl are true and eom:cllO the best ofthcir knowledge. infOrmalion, and belief. This verification is made suhje<:11o the penalties of I R Po, C,S,A. ~904 rclutinlllo WlSWorn INsil;c.lilln 10 authoritics, DATED: g )'3/D ").- , f [ - rJ - <J L DATED: ~_~.~ FA_/JJ-- STEi>l-IANlE JANE RAN '- ~U' e// <--" EXHIBIT "A" SAIDIS. GUIDO, SHUFF & MASLAND 26 W, High Street Carlisle, PA II II I I SANDRA J. BASEHORE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 94- {.t,?P CIVIL TERM CARRIE L_ DOHERTY and STEPHEN MORGAN, Defendants ORDER AND NOW, this .:J9#. day of November, 1994, upon consideration of the attached Stipulation, it is hereby ordered and decreed that primary legal and physical custody of Allison Marie Morgan, D.O.B. 10-31-94, shall be placed in her maternal grandmother, the Petitioner, who shall act as legal guardian of said child, subject to the terms and conditions of the attached Stipulation. BY THE COURT, /S/ ~/ [. ~-1 rf J. TRUE C~F~~~E~:~ In TMtlfnOnY Court at Can.. PI. am! ... "" .. said I 'T1~ ~ This .:J~ _~ 0 j::. :~ '-E? L PtOtl\Onota SAIDIS, GUIDO, SHUFF & MASLAND 26 W. High Street Carlisle, PA SANDRA J. BASEHORE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v_ 94- CIVIL TERM CARRIE L. DOHERTY and STEPHEN MORGAN, Defendants STIPULATION FOR CUSTODY AND NOW, this c23,-dday of ;{)Oi/[i)llOC"r, 1994, comes SANDRA J. BASEHORE, CARRIE L. DOHERTY and STEPHEN MORGAN, to stipulate as follows: (1) Your Petitioner is Sandra J. Basehore, an adult individual who currently resides at 501A E. Elmwood Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17055. (2) Respondent Carrie L. Doherty, who is the daughter of the Petitioner, is a minor individual who currently resides with the Petitioner at 50lA E. Elmwood Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17055. (3) Respondent Stephen Morgan is a minor individual, who currently resides with his parents at 600 E. Coover Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. (4) The Petitioner is the maternal grandmother of one child, Allison Marie Morgan, D.O.B. 10-31-94. (5) The Respondents are the natural parents of said Allison Marie Morgan. (6) The parties agree that the Petitioner shall be the legal guardian of the said minor child, and shall have primary legal and physical custody of the said child. (7) The parties further agree that periods of partial :AIDIS, GUIDO, SHUFF & MAS LAND 26 W, High Street Carlisle, PA custody/visitation shall be enjoyed by the Respondents at times to be mutually agreed upon by the parties. (8) The parties further agree that your Petitioner and legal guardian will have primary responsibility for financial and emotional support, including but not limited to healthcare coverage and decisions, education, and welfare of said child. (9) The parties further agree that ~he Petitioner shall take the said child as a dependent deduction for Pennsylvania and federal income tax purposes. (10) The parties further agree that no child support will be paid by the Respondents until such time as they are able to provide financially for the support of said child. (11) The parties desire that this agreement be evidenced by an Order of Court. (12) The parties further agree that this Stipulation may be amended as circumstances change. WHEREFORE, the parties hereto request Your Honorable Court to enter an order awarding legal custody to the Petitioner, subject to the terms as provided herein. 0,~fi? ~J- ).,~ W1.tness f'. ~ -~ ~\ ~ ~~~, VJ?;~~~ Wi tnes (j ~ -I/!A-/f{; ~~~~ / andra J. sehore cr&tii ~.~?;tr~~ ~~:a~~k~) ~~ ~, ~ ~ ~~ ~ ~ :::") (;T~ r.,: ~ , ""', - C. . '. ) ,- 'I ":'( ) 'iil -'~".' ..<\ ~ :~) :2 ::~-\ (J" --<. STEPHANIE JANE RANFT AND ERROL THEODORE RANFT PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 02-3893 CIVIL ACTION LAW CARRIE LYNN DOHERTY, STEPHEN SHAWN MORGAN AND SANDRA JANE BASEHORE DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, August 21, 2002 . upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Thursday, September 12,2002 at 1:00 PM 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 Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: Isl Dawn S. Sunda.y. Esq. Custody Conciliator ~ 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 ATIORNEY AT ONCE. IF YOU DO NOT HAVE AN ATIORNEY 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 "~b .~ ~ /4.;7 C"o.~.~ '~<r~ ~~ ~17.~".g ~r ~~(.s)~ ~ (or?-C!~'$ 'v'IMtlt'),SNN3d lJNnOO Of-1I;r)dj8Wno IE: :1/ UV cZ tJn-v ZO 1J:N10ivOH10'i(J :.:id-L ::10 301:1.-/0--0371.:1 AVd 3 0 zoot STEPHANIE JANE RANFT and ERROL THEODORE RANFT, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 02-3893 CNIL ACTION LAW CARRIE LYNN DOHERTY, STEPHEN SHAWN : MORGAN and SANDRA JANE BASEHORE, Defendant ORDER OF COURT AND NOW, this 28th day of August, 2002, the Conciliator, being advised by Plaintiffs counsel that all custody issues have been resolved by agreement of the parties, hereby relinquishes jurisdiction. The Custody Conciliation Conference scheduled for September 12, 2002 is canceled. FOR THE COURT, D~A Custody Conciliator o 1') v>. ~ '-0 Q ~ ~.~1.:~ fl] {1' ~~... ~'c ~t: ~ 7.-:() ~:-C'; 7'"c':- ~ v- n '::~1". ~ -,"\' i::;;':' ,\-ro1 "~C? 1:;~~ ::J..C) .J'" :....J -.'-\ ~ :.:::. --- --- - <1" STEPHANIE JANE RANFT and ERROL THEODORE RANFT, PLAINTIFFS vs. CARRIE LYNN DOHERTY, STEPHEN SHAWN MORGAN and SANDRA JANE BASEHORE, DEFENDANTS : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA : NO. 02-3893 CIVIL TERM : CIVIL ACTION - LAW : ACTION FOR CUSTODY STIPULATION FOR AGREED ORDER OF CUSTODY Plaintiffs are STEPHANIE JANE RANFT and ERROL THEODORE RANFT (hereinafter known as "Aunt and Uncle") who currently reside at 212 North King Street, Leesburg, Virginia, 20176. First Defendant is CARRIE LYNN DOHERTY (hereinafter known as "Mother") who currently resides at 504 Fourth Street, Apartment B, New Cumberland, Cumberland County, Pennsylvania, 17070. Second Defendant is STEPHEN SHAWN MORGAN (hereinafter known as "Father") who currently resides at 27 West Coover Street, Apartment B, Mechanicsburg, Cumberland County, Pennsylvania, 17055_ Third Defendant is SANDRA JANE BASEHORE (hereinafter known as "Grandmother') who currently resides at 134 Lancaster Boulevard, Mechanicsburg, Cumberland County, Pennsylvania, 17055_ ALLISON MARIE MORGAN (hereinafter known as "Allison"), born on October 31, 1994, is the natural child of Mother, CARRIE LYNN DOHERTY, and Father, STEPHEN SHAWN MORGAN, the natural grandchild of Grandmother, SANDRA JANE BASEHORE, the natural niece of Aunt and Uncle, STEPHANIE JANE RANFT and ERROL THEODORE RANFT, and is the subject of this Stipulation for Agreed Order of Custody, It is Mother, Father, Grandmother, and Aunt and Uncle's belief that it is in the best interests of this minor child to have a meaningful ongoing relationship with Mother, Father, Grandmother, and Aunt and Uncle provided the child is in a safe environment, WHEREFORE, Plaintiffs, STEPHANIE JANE RANFT and ERROL THEODORE RANFT, and Defendants, CARRIE LYNN DOHERTY, STEPHEN SHAWN MORGAN and SANDRA JANE BASEHORE have entered into a mutual agreement regarding the custody of the child, ALLISON MARIE MORGAN, and respectfully request this Honorable Court to enter the following Order: L Aunt and Uncle, STEPHANIE JANE RANFT and ERROL THEODORE RANFT, shall have Full Legal Custody of the minor child, ALLISON MARIE MORGAN, Legal custody being defined as the legal right to make major decisions affecting the upbringing of the child, including, but not limited to, medical, religious and educational decisions. In all decisions including, but not limited to, the aforementioned types of decisions, the parties have agreed Aunt and Uncle shall have the primary decision-making ability for the minor child, Nevertheless, Aunt and Uncle have agreed they shall seek input from Mother, Father and Grandmother regarding these types of decisions and shall consider these individuals' input when making any major decisions for Allison, Aunt and Uncle have also agreed to provide Mother, Father and Grandmother with information in a timely manner regarding these decision-making circwnstances in Allison's life. 2, Aunt and Uncle shall have Primary Physical Custody and Mother, Father and Grandmother shall share Partial Physical Custody of the child, ALLISON MARIE MORGAN. 3. Mother, Father and Grandmother may contact Aunt and Uncle to schedule visitation with Allison for any periods of time they are traveling and will be in the area of Leesburg, Virginia, 4, Aunt and Uncle shall cooperate with Mother, Father and Grandmother to make Allison available for periodic weekend visits during the school year as mutually agreed upon by the parties. Additionally, Mother, Father and Grandmother shall each have the ability to request one to two (1-2) weeks of visitation during Allison's summer vacation from school as mutually agreed upon by the parties. 5. Aunt and Uncle agree to keep Mother, Father and Grandmother fully aware and informed of any successes, difficulties, activities, emergencies, etc, in which Allison becomes involved. 6, The parties agree to share holidays as mutually agreed upon by the parties. 7. The parties agree Aunt and Uncle shall have primary responsibility for Allison financially, for medical insurance, health care and her education. 8. The parties agree Aunt and Uncle and Grandmother shall share equally the income tax deduction for Allison for 2002 and Aunt and Uncle shall have the income tax deduction for Allison beginning 2003, 9, Aunt and Uncle agree they shall not seek any child support from Mother and Father. 10, The parties shall be free to mutually agree to alter and/or change the terms of this agreement. If the alteration and/or agreement is permanent and/or a change which will occur on numerous occasions, the parties agree the alteration and/or change shall be in writing and signed by all parties. WITNESSES: ~~4!lf7 CARRIE L BERTY ~\\ A)~~ N SHAWN MORGAN ~~ a~~ ""'-SANDRA JA$BASEHORE COMMONWEALTH OF PENNSYL VANIA COUNTY OF c:.~\)~.,\\Q"'-C\ On this, the (i..[*'- day of ~ ~ , 2002, before me, a Notary Public for the Commonwealth of Pennsylvania, the un erslgned officer, personally appeared STEPHANIE JANE RANFT known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Stipulation for Agreed Order of Custody, and acknowledged that she executed the same for the purpose therein contained. SS: IN WllNESS WHEREOF, I have set my hand and notarial seal. ~~~~~~ Notary Public<\ My Commission Expires: ~ l( )~OOS NotariaJ SeeI ~~. No~Publk: My~~~~ COMMONWEALTH OF PENNSYLVANIA COUNTY OFC lA.~,:\)e..,\Q",d On this, the {4-\.~ day of ~ t d- , 2002, before me, a Notary Public for the Commonwealth of Pennsylvania, the um~;;;;igned officer, personally appeared ERROL THEODORE RANFT known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Stipulation for Agreed Order of Custody, and acknowledged that he executed the same for the purpose therein contained. SS: IN WIlNESS WHEREOF, I have set my hand and notarial seal, ~ij(,~ Notary PublIc My Commission Expires:~ 4.) e>.OO s Notarial Seal KI-= R. Hanford, Notary Public Meet rg Bore, Cumberland County My Comml88lon Expires Apr. 4, 2005 COMMONWEALTH OF PENNSYL VANIA COUNTY OF c.u..~be,\ 6...~c\ On this, the J~ dayof~.u;ct- ,2002, before me, a Notary Public for the Commonwealth of Pennsylvania, the untlersigned officer, personally appeared CARRIE LYNN DOHERTY known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Stipulation for Agreed Order of Custody, and acknowledged that she executed the same for the purpose therein contained. SS: IN WIlNESS WHEREOF, I have set my hand and notarial seal, ~l.~ f2- ,~~ Notary Public My Commission Expires:~ y')C200S Notarial Seal KI:::::t,R' Hanford, Notary Public MecIt rg Bore, Cumberland County My CommIsslon expires Apr, 4, 2005 COMMONWEALTH OF PENNSYLVANIA COUNTY OFCl.L"<<\'oe..,\o..~d On this, the Jq~ day of ~ ,2002, before me, a Notary Public for the Commonwealth of Pennsylvania, the derslgned officer, personally appeared STEPHEN SHAWN MORGAN known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Stipulation for Agreed Order of Custody, and acknowledged that he executed the same for the purpose therein contained. SS: IN WIlNESS WHEREOF, I have set my hand and notarial seal, ~~,t-~~ Notary Public~ My Commission Expires: ~ L\ 1(;)00> NolariaI Seal ~ Hanford. Notary Public MId Boro. CumberIlind CClunIy My ComIlIl8Slon Expires Apr. 4, 2005 COMMONWEALTH OF PENNSYLVANIA COUNTY OF Cl.L~e..\\.O-.W On this, the J ~ day of ~ r-ct- , 2002, before me, a Notary Public for the Commonwealth of Pennsylvania, the erslgned officer, personally appeared SANDRA JANE BASEHORE known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Stipulation for Agreed Order of Custody, and acknowledged that she executed the same for the purpose therein contained, SS: IN WITNESS WHEREOF, I have set my hand and notarial seal. ~~,~~ Notary Public~ My Commission Expires~ L\l~()(JS- Notarial Seal = Hanford. NotaJy Public MId Boro, Cumberland C9unIY My Comrnlliillon Expires Apr. 4, 2005 0 a 0 c: r'(:.\ -" ~ .". ." cn ,~ '"-- !:prr ~"') .c..:J:J f'..,) :ZC' t-~ v~ ~,~~ = ~.~? c:) ~CJ "", -T- ;5 -n ~(') :Jr: ('j .' :>0 1',:, t3t r't c: o:;! ~ ~) ~ Ul STEPHANIE JANE RANFT and ERROL THEODORE RANFf, PLAINTIFFS VS. CARRIE LYNN DOHERTY, STEPHEN SHAWN MORGAN and SANDRA JANE BASEHORE, DEFENDANTS : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA : NO.02-3893 CIVIL TERM : CIVIL ACTION - LAW : ACTION FOR CUSTODY QRDER OF COURT AND NOW, this r..J/#- day of ~ , 2002, upon consideration of the attached Stipulation for Agreed Order of Custody, Plaintiffs, STEPHANIE JANE RANFf and ERROL THEODORE RANFf, shall have FULL LEGAL AND PRIMARY PHYSICAL CUSTODY and Defendants, CARRIE LYNN DOHERTY, STEPHEN SHAWN MORGAN and SANDRA JANE BASEHORE, shall have PARTIAL PHYSICAL CUSTODY of the minor child, ALLISON MARIE MORGAN, in accordance with the language contained in the within Stipulation. . ~ tr~~ofl ~~ to: 2kp'he~ {f)o~,\o.~ fArri e. bo heRtr .2 0.. \'\ d ra. 8o.s e. 'h 0 Re.. J. VINV^lASNN3d AlNn08 or':'(lI:Ei8I;\JnO L I :6 !,gt 9,. d3S 20 AI::f\110,'n.J.'c;;;.~ :JO 3:Ji:UJ-Gj'jU STEPHANIE JANE RANFI' and ERROL THEODORE RANFf, PLAINTIFFS vs. CARRIE LYNN DOHERTY, STEPHEN SHAWN MORGAN and SANDRA JANE BASEHORE, DEFENDANTS : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA : NO.02-3893 CIVIL TERM : CIVIL ACTION . LAW : ACTION FOR CUSTODY AFFIDAVIT OF S:ERVICE CERTlDED MAIL COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF CUMBERLAND Be it known, that on theds*' day of ~~ , 2002, before me, the subscriber, a Notary Public, personally appeared SUSAN KAY CANDIELLO, who, being duly sworn according to law, did depose and state as follows: 1. I am an attorney licensed to practice law in the Commonwealth of Pennsylvania. 2. I represent Stephanie Jane Ranft and Errol Theodore Ranft, Plaintiffs in the above-captioned matter. 3. On August 27, 2002, a true and correct copy of the Complaint for Custody, was deposited for delivery with the U.S. Postal Service in Mechanicsburg, Pennsylvania, being Certified/First Class Mail, restricted delivery, return receipt requested, Article Nos. 70012510 000344399536,7001 2510 000344399550, and 7001 2510 000344399543, and addressed to the Defendants, Carrie Lynn Doherty at 504 Fourth Street, Apt. B, New Cumberland PA 17070; Stephen Shawn Morgan at 27 West Coover Street, Apt. B, Mechanicsburg PA 17055; and Sandra Jane Basehore at 134 Lancaster Boulevard, Mechanicsburg PA 17055, respectively, 4. The return receipt cards signed by the Defendants, Carrie L. Doherty, Stephen S. Morgan, and Sandra J. Basehore showing dates of service of August 30, 2002, September 4, 2002, and August 28,2002, respectively, are attached hereto as Exhibit "A". 5. Service by certified mail meets the requirements of Pa.R.c.P. 404(2) and Pa.R.C.P. 403. SWORN TO AND SUBSCRIBED before me, a Notary Public, this d ~ day of ~te.5\ ,2002. ~~~ .l~ Notary Public . My Commission Expires: G.fu-O- Lj) ~ S Notartal Seal I~ Hanford, NolaJy Public My Bolo, CumbtlrIBncI ~ Commlsillon ExpIres Apr. 4, 2005 ,~ . Complete Items 1, 2,"fI!l~, Also complete Item 4 if RestrIcted ~'ls desired. . Print your name and ~ on the__ so that we ClIIn return the. card to you. . Attach this card to the back of the ma/lplece, or on the front if space permits. 1, ArtIcle Addr8sSed to: LO-\\\e Ll;-\\\f'\ Oo\\ect"4 S)'\ f6U.(~2;T("ed) ~pt-, B A>M C.u..",l)€\IOJ\.o Pf+ C'I'1DflO ItE~CTlD DELIVERY 3. Service Type Ji( Certlfled Mail 0 Express Mail o Reglstlll8d 0 Return Recelpt fDr o Insured Mail 0 C.Q,D. 4. FWII!illld~...FeJtJ 2. Article Number (Copy from service label) - 7001 2510 0003 4439 ,1"5 FOITII 3811, July 1l1l18 ~ FIIlum ReceIpl 9536 10251& LOII2 . ~"""1,2,"'S.MIlIl rILl item 4 if Restricted Deli-V Is desired, . Print your name and address on the reverse so that we can retUrn the card to you. . Attach this card to the back of the mallpiece, or on the front if space permits. 1. ArtIcIe~to: ~~~" 'S\\.(lW~ "'()(~At\ dC) l).)e5t C<$J\Jes ~e~Jft. B 1'1\C:c.A(),,~\CSb~ Pit /1)055" RESTRICTED DELIVERY 2. Article Number (Copy from service label) '4. . o Express Mail o Return ReceIpt lot Mero~ ail 0 C,O.D, DoIMoy'1 (I!llfnI ,..., _ ~ 7001 2510 0003 4439 9550 102&15-00-M-IlfI!' P8 FOITII 3811, July 1999 ~ - ReceIpl /, Exhibit" A" ~ J. .. 'inplete Items 1, 2, and 3. Also complete 11Im 4 if Restricted DellvllI)I is desired, . PrInt your name and address on the reverse 80 that we can return the card to you, . Altach this card to the back of the mailpiece, or on the front if space permits, 1. Article Addressed to: &lM..~C\ ~ 565e.-~<;:e. \34.. L6J\CR5te\ &uJ-euC1t""d ~~~tc'SbLl~ fit Il')D~ RESTRICTEI DELIVERY o. Is delivery add dilferent from Item 1? 0 If YES, enter delivery address below: 0 3, Service Type ~nied Mail 0 Express Mail o Registered 0 Retum Receipt for Mdrclw1dile o Insured Mail 0 C,O.O. 4.........llrIlMIoy? t&fra F-.J 2. Miele Number (Copy from servioe label) 7001 aS10 0003 ~43~ ~S43 I"S Form 3811, July 1_ ~ ReI.." Receipt 102595.00.M.0952 ........,...-u_ - Exhibit" A" continued () ~ "Urn ~93 ~() 5>g ~ () ~ ~.~ tjc: -c. -< .-, .-.., --u ~-'-' <=:> '<.,.} (",) - ) ~ ::0 -< STEPHANIE JANE RANFT AND ERROL THEODORE RANFT, PLAINTIFFS : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 02 - 3893 CIVIL ACTION - LA W CARRIE LYNN DOHERTY, STEPHEN SHAWN MORGAN, and SANDRA JANE BASEHORE, DEFENDANTS : IN CUSTODY STIPULATION FOR AGREED ORDER REGARDING CUSTODY Plaintiffs are Stephanie Jane Ranft, and Errol Theodore Ranft, (hereinafter referred to as "Aunt and Uncle") who currently reside at 1005 Rosemont Ave, Frederick, Maryland. Defendants are: Carrie Lynn Doherty, (hereinafter referred to as "Mother"), who currently resides at 451 Valley Street, Marysville, Perry County, Pennsylvania, 17053. Stephen Shawn Morgan, (hereinafter referred to as "Father"), who currently resides at 109 Twin Mills Road, Apartment 11, Dillsburg, York County, Pennsylvania, 17019. Sandra Jane Basehore, (hereinafter referred to as "Grandmother"), who currently resides at 134 Lancaster Boulevard, Mechanicsburg, Cumberland County, Pennsylvania, 17055. Allison Marie Morgan (hereinafter referred to as "Child"), was born on October 31, 1994, and is the natural child of Mother, Carrie Lynn Doherty, and Father, Stephen Shawn Morgan. She is the grandchild of Sandra Jane Basehore and the niece of Stephanie Jane Ranft and Errol Theodore Ranft. She is the subject of this Stipulation and the above-referenced parties believe that the best interests of the child will be served by the terms of this Stipulation. WHEREFORE, the parties have entered into a mutual agreement regarding the custody of the child, Allison Marie Morgan, and respectfully request this Honorable Court to enter the following Order: 1. Mother shall have full legal custody of the minor child, Allison Marie Morgan. Legal custody is defmed as the legal right to make major decisions affecting the upbringing of the child, including, but not limited to, medical, religious, and educational decisions. Although Mother has full legal custody of the minor child, Mother agrees to accept input from Father, Grandmother, and Aunt and Uncle regarding such major decisions. Mother will provide Aunt, Uncle, Father, and Grandmother with information in a timely manner regarding these decision- making circumstances in Allison's life. 2. Mother shall have primary physical custody of the child. Father and Grandmother shall each have periods of partial physical custody of the child. Aunt and Uncle may also have periods of partial physical custody with the child. 3. Father, Grandmother and Aunt and Uncle may contact Mother to schedule visitation with Allison for any periods of time they will be in the area of Marysville, Pennsylvania. 4. Mother shall cooperate with Father, both Grandmothers, and Aunt and Uncle to make Allison available for periodic weekend visits during the school year as mutually agreed upon by the parties. Additionally, Father, Grandmother, and Aunt and Uncle shall each have the ability to request one to two weeks of visitation during Allison's summer vacation from school as mutually agreed upon by the parties. SI.~~ slWl ~ MMBor $'" .u.il~..Ml'1Uh ift "hil.i 9tltlp1llll; d In !he HI,t elf ~lId.. .\>R-t f~ iJ(i)./ ~ . 6. Mother agrees to keep Father, Grandmother, and Aunt and Uncle fully aware and informed of any successes, difficulties, activities, emergencies, etc., in which Allison is involved. 7. The parties agree to share holidays as mutually agreed upon by the parties. 8. The parties agree that Mother shall have primary responsibility for Allison financially, for medical insurance, health care, and her education. WITNESSES: /;1~1J1/~ s{ep~~ ~ Date: ~111/0ft:; - ~v; Errol Theodore Ranft Date: 2 - ( ~ ;' 0 (, carrie Lynn DohertY Date: +/,) "1 /OU; Date: c?,,;CJ- {)U /"...) g~ N -"1 --.~. . fv I ---..~ -,- ". '- STEPHANIE JANE RANFT AND ERROL THEODORE RANFJ, PLAINTIFFS V. CARRIE LYNN DOHERTY, STEPHEN SHAWN MORGAN, and SANDRA JANE BASEHORE, DEFENDANTS . / OCT 1 (l 7006 l~l : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO, 02 - 3893 CIVIL ACTION - LAW : IN CUSTODY ORDER AND NOW, this 17~aYOf ~ , 2006, having reviewed the attached agreement between the parties, which was filed October 12,2006, it is hereby ORDERED and DECREED that this Stipulation shall be entered as an Order of Court. cc: 4e Adams, Esquire, for mother "Stephen Shawn Morgan, father ~phanie and Errol Ranft ~ ."Mne Basehore J. 'vlNVIiIASNN:!;d JJ.NnO;:l ijt'""0J:3f1/1Vna Dc :8 U~ 8 J 130900Z J..tN1DtvOH-iOf"rl,iIllit) 3Gt::!:1t.l"W78 .-