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IN TIlE COURT OF COMMON PLBAS OF CUMBERLAND COUNTY
WILLIAM T. GUY
and PATRICIA A. GUY,
Plaintiffs
No. ql,. J~-(' CwJ I.LV"-
v.
CIVIL ACTION-LAW
IN CUSTODY
BAN TA,
Defendant
ORDER OF COURT
AND NOW, TO WIT, this
day of
,
1996, it is hereby ORDERED AND DECREED that the attached
Stipulation for custody is made an Order of this Court and said
Stipulation is adopted in its entirety and incorporated herein as
an Order of the Court.
BY THE COURT:
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IN 'mB COURT OF COIOION PLEAS OF CUMBERLAND COUNTY
WILLIAM T. GUY .
. ~ '"/."
and PATRICIA A. GUY, . No. rJ~ - -3 s'l.
.
Plaintiffs :
v. .
.
. CIVIL ACTION-LAW
.
. IN CUSTODY
.
BAN TA,
Defendant .
.
STIPULATION FOR CUSTODY
AND NOW, this
ISM
, 1995, the
day of December
parties, having reached an agreement with regard to the best
interests of the subject minor child, KIM TA, born November 6,
1982, do hereby agree and stipulate as follows:
1. primary legal and physical custody of the subject child
shall be with William T. and patricia A. Guy, 333 Evergreen street,
New Cumberland, PA 17070.
2. The Defendant is the child's natural father, Ban Ta, 129
Bridge street, New Cumberland, PA 17070 (hereinafter referred to
as "Father"). Father shall have liberal rights of visitation and
partial physical custody as the parties may mutually agree.
3. The parties agree that day to day decisions of a routine
nature, including but not limited to bed time, homework, day-to-day
social activities, customary for the child's age and maturity
shall be made by the GUYs.
4. The parties agree that if either of them move from
Cumberland County, notice in writing shall be given to the other
party at least ninety (90) days in advance of said move.
..,
..
~. The partie. agree to submit to the Court of Common Pleas
of Cumberland County, Pennsylvania, a Consent Order of Court for
oustody and partial oustody in a form identical to that attached
hereto, provision. of which are hereby incorporated by reference in
this stipulation.
For thi. purpose, the parties hereby submit themselves to
the oontinuinq jurisdiotion of the Court of Common Pleas of
Cumberland County, Pennsylvania, which court shall have
juri.diotion over all matters relating to the custody of the minor
ohild regardless or the residence or domicile of the parties or the
ohild.
6. The GUYs have employed and have had the benefit of
counselor Terry Peyser Blynn, Esquire, 1516 Second Avenue, York,
Pennsylvania, 17403 as her attorney.
The Father has been advised of his right to receive
independent lagal advice from counsel of his selection in order to
be fully informed as to his or her legal rights and obligations,
and to have an attorney review this Stipulation and Proposed Order.
Father has had this document read to him in his native language,
Vietnamese.
However, Father has refused such representation and has chosen
to refuse to confer with counsel. Accordingly, all parties
acknowledge and accept that this Agreement is, under the
oiroumstances, fair and equitable, and it is being entered into
freely and voluntarily after having received such advice and with
such knowledge, and that execution of this Agreement is not a
result of any duress or undue influence and that it is not the
result of any collusion or improper or legal agreement or
agreements.
7. At all times the parties shall encourage and foster in
the child sincere respect and affection for both the Father, Ban
Ta, and Patricia and William GUY, and the parties shall not hamper
the natural development of the child's love and respect for the
ei ther of the parties.
Each party shall keep the other party
advised as to any serious illness or any major development with
respect to the child.
s. This stipulation and subsequent Order of Court shall
continue in full force and effect until further Order of Court and
lor amended agreement in writing between the parties.
17. The parties hereby waive their right to present this
Stipulation in open court or to have their case heard by the Court
at this
If" -
, ESQUIRE
;;.2-/61'-
Iu;ac"'~.., 7:~
WILLIAM T. GUY
::Pn:t~:..;~, a, &Uf
PATRICIA A. GUY (,
.
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ESQUIRE
BAN TA
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IN TIIB COUR'l' OF COIIMON PLEAS OF CUMBERLAND COUHTY
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WILLIAM T. GUY . 1t.. 3{'(.. ~ I~
.
and PATRICIA A. GUY, . No.
.
Plaintiffs .
.
v. .
.
. CIVIL ACTION-LAW
.
. IN CUSTODY
.
BAN TA, .
.
Defendant .
.
1996, it is hereby ORDERED AND DECREED that the attached
Stipulation for Custody is made an Order of this Court and said
Stipulation is adopted in its entirety and incorporated herein as
an Order of the Court.
,
ORDER OF COURT
AND NOW, TO WIT, this
day of
BY THE COURT:
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IN THB COURT OF COMMON PLEAS OF CUllBBRLAHD COUNTY
WILLIAM T. GUY
and PATRICIA A. GUY, .
.
Plaintiffs .
.
v. .
.
.
.
.
.
BAN TA,
Defendant .
.
I '1.,-~ Cl..~ -r.;....--
No. q"
CIVIL ACTION-LAW
IN CUSTODY
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to the :bes~7 !
....
STIPULATION FOR CUSTODY
AND NOW, this
,gM
day of Dc!L' e rn b~ r
parties, having reached an agreement with regard
interests of the subject minor child, KIM TA, born November 6,
1982, do hereby agree and stipulate as follows:
1. Primary legal and physical custody of the subject child
shall be with William T. and patricia A. Guy, 333 Evergreen Street,
New Cumberland, PA 17070.
2. The Defendant is the child's natural father, Ban Ta, 129
Bridge street, New Cumberland, PA 17070 (hereinafter referred to
as "Father"). Father shall have liberal rights of visitation and
partial physical custody as the parties may mutually agree.
3. The parties agree that day to day decisions of a routine
nature, including but not limited to bed time, homework, day-to-day
social activities, customary for the child's age and maturity
shall be made by the GUYs.
4. The parties agree that if either of them move from
Cumberland County, notice in writing shall be given to the other
party at least ninety (90) days in advance of said move.
5. The parties agree to submit to the Court of Common Pleas
of Cumberland County, Pennsylvania, a Consent Order of Court for
custody and partial custody in a form identical to that attached
hereto, provisions of which are hereby incorporated by reference in
this stipulation.
For this purpose, the parties hereby submit themselves to
the continuing jurisdiction of the Court of Common Pleas of
Cumberland County, Pennsylvania, which court shall have
jurisdiction over all matters relating to the custody of the minor
child regardless of the residence or domicile of the parties or the
child.
6. The GUYs have employed and have had the benefit of
counsel of Terry Peyser Slynn, Esquire, 1516 Second Avenue, York,
Pennsylvania, 17403 as her attorney.
The Father has been advised of his right to receive
independent legal advice from counsel of his selection in order to
be fully informed as to his or her legal rights and obligations,
and to have an attorney review this Stipulation and Proposed Order.
Father has had this document read to him in his native language,
Vietnamese.
However, Father has refused such representation and has chosen
to refuse to confer with counsel. Accordingly, all parties
acknowledge and accept that this Agreement is, under the
circumstances, fair and equitable, and it is being entered into
freely and voluntarily after having received such advice and with
such knowledge, and that execution of this Agreement is not a
i
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,result of any duress or undue influence and that it is not the
result of any collusion or improper or legal agreement or
agreements.
7. At all times the parties shall encourage and foster in
the child sincere respect and affection for both the Father, Ban
Ta, and Patricia and William Guy, and the parties shall not hamper
the natural development of the child's love and respect for the
ei ther of the parties.
Each party shall keep the other party
advised as to any serious illness or any major development with
respect to the child.
s. This Stipulation and subsequent Order of Court shall
continue in full force and effect until further Order of Court and
lor amended agreement in writing between the parties.
17. The parties hereby waive their right to present this
Stipulation in open court or to have their case heard by the Court
'If'- -
, ESQUIRE
').2./q,-
a,1"t.'t'Lc.~ T.4;t,."p
WILLIAM T. GUY .:/
:Pat.: .,; fA. ()., &, '1
PATRICIA A. GUY (
.
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ESQUIRE
BAN TA
.
JAN L:; .'" (f
IN THE COURT OF CONNON PLEAS OF CUMBERLAND COUNTY
WILLIAM T. GUY
and PATRICIA A. GUY,
Plaintiffs
'1(, . , j $"'(. 0."'-t Tu-..-.
No.
v.
BAN TA,
CIVIL ACTION-LAW
IN CUSTODY
Defendant
.
.
.
.
ORDER OF COURT
AND NOW, TO WIT, this
day of
,
1996, it is hereby ORDERED AND DECREED that the attached
Stipulation for CUstody is made an Order of this Court and said
Stipulation is adopted in its entirety and incorporated herein as
an Order of the Court.
BY THE COURT:
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IN TUB COURT OF COJOION PLBAS OF CUNBBRLAND COUNTY
WILLIAM T. GUY
and PATRICIA A. GUY,
Plaintiffs
.
.
.
.
No. '7c. - h(; 0.;...:J J:..--
v.
I
CIVIL ACTION-LAW
IN CUSTODY
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to the best
BAN TA,
.
.
Defendant
.
.
STIPULATION FOR CUSTODY
AND NOW, this
I gU
day of Decem br' r
parties, having reached an agreement with regard
interests of the subject minor child, KIM TA, born November 6,
1982, do hereby agree and stipulate as follows:
1. Primary legal and physical custody of the subject child
shall be with William T. and Patricia A. Guy, 333 Evergreen street,
New Cumberland, PA 17070.
2. The Defendant is the child's natural father, Ban Ta, 129
Bridge street, New Cumberland, PA 17070 (hereinafter referred to
as "Father"). Father shall have liberal rights of visitation and
partial physical custody as the parties may mutually agree.
3. The parties agree that day to day decisions of a routine
nature, including but not limited to bed time, homework, day-to-day
social activities, customary for the child's age and maturity
shall be made by the Guys.
4. The parties agree that if either of them move from
Cumberland County, notice in writing shall be given to the other
party at least ninety (90) days in advance of said move.
5. The parties agree to submit to the Court of common Pleas
of Cumberland County, Pennsylvania, a consent Order of Court for
custody and partial custody in a form identical to that attached
hereto, provisions of which are hereby incorporated by referenoe in
this stipulation.
For this purpose, the parties hereby submit themselves to
the continuinCJ jurisdiotion of the Court of Common pleas of
cumberland County, pennsyl vania, which court shall have
jurisdiction over all matters relatinCJ to the custody of the minor
ohild regardless of the residence or domicile of the parties or the
child.
6. The Guys have employed and have had the benefit of
counsel of Terry Peyser Blynn, Esquire, 1516 second Avenue, York,
pennsylvania, 17403 as her attorney.
The' Father has been advised of his right to receive
independent legal advice from counsel of his selection in order to
be fully informed as to his or her legal rights and obliCJations,
and to have an attorney review this stipulation and proposed Order.
Father has had this document read to him in his native languaCJe,
vietnamese.
However, Father has refused such representation and has chosen
to refuse to confer with counsel. AccordinCJ1y, all parties
acknowledCJe and accept that this ACJreement is, under the
circumstances, fair and equitable, and it is beinCJ entered into
freely and voluntarily after having received such advice and with
such knowledge, and that execution of this Agreement is not a
result of any duress or undue influence and that it is not the
result of any collusion or improper or legal agreement or
agreements.
7. At all times the parties shall encourage and foster in
the child sincere respect and affection for both the Father, Ban
Ta, and Patricia and William Guy, and the parties shall not hamper
the natural development of the child's love and respect tor the
ei ther of the parties.
Each party shall keep the other party
advised as to any serious illness or any major development with
respect to the child.
S. This Stipulation and subsequent Order of Court shall
continue in full force and effect until further Order of Court and
lor amended agreement in writing between the parties.
17. The parties hereby waive their right to present this
stipulation in open court or to have their case heard by the Court
tt~ l'e,~ 7:.4;t,~<-~
WILLIAM '1'. GUY J
'Pfd,: .' ,. 'A , 0. . 1:11 ',-
PATRICIA A. GUY f
,
ESQUIRE
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BAN'l'A
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,
IN THB COURT OF CONNON PLEAS OF CUMBERLAND COUNTY
WILLIAM '1'. GUY .
. G;;./ 1J-
and PATRICIA A. GUY, . No. 11. 3-';1..
.
Plaintiffs .
.
v. .
.
. CIVIL ACTION-LAW
.
. IN CUSTODY
.
BANTA,
Defendant .
.
ORDBR OF COURT
AND NOW, TO WIT, this
day of
,
1996, it is hereby ORDERED AND DECREED that the attached
StipUlation for Custody is made an Order of this Court and said
Stipulation is adopted in its entirety and incorporated herein as
an Order of the Court.
BY THE COURT:
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IN THB COURT OF COIOlON PLEAS OF CUMBERLAND COUNTY
WILLIAM '1'. GUY
and PATRICIA A. GUY,
Plaintiffs
No. q{.'1~-{. (1;.( "I.t-
v.
CIVIL ACTION-LAW
IN CUSTODY
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BANTA,
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Defendant
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STIPULATION FOR CUSTODY
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AND NOW, this
1 gu.
. ("'.J
, 1995, :the";'
day of De(~ernbcr
parties, having reached an agreement with regard to the best
interests of the subject minor child, KIM TA, born November 6,
1982, do hereby agree and stipulate as follows:
1. Primary legal and physical custody of the subject child
shall be with William T. and Patricia A. GUY, 333 Evergreen street,
New CUmberland, PA 17070.
2. The Defendant is the child's natural father, Ban Ta, 129
Bridge Street, New Cumberland, PA 17070 (hereinafter referred to
as "Father"). Father shall have liberal rights of visitation and
partial physical custody as the parties may mutually agree.
3. The parties agree that day to day decisions of a routine
nature, including but not limited to bed time, homework, day-to-day
social activities, customary for the child's age and maturity
shall be made by the GUYs.
4. The parties agree that if either of them move from
Cumberland County, notice in writing shall be given to the other
party at least ninety (90) days in advance of said move.
.
5. The parties agree to submit to the Court of Common Pleas
of Cumberland county, Pennsylvania, a Consent Order of Court for
custody and partial custody in a form identical to that attached
hereto, provisions of which are hereby incorporated by reference in
this stipulation.
For this purpose, the parties hereby submit themselves to
the continuing jurisdiction of the Court of Common Pleas of
Cumberland County, Pennsyl vania, which court shall have
jurisdiction over all matters relating to the custody of the minor
child regardless of the residence or domicile of the parties or the
child.
6. The GUYs have employed and have had the benefit of
counsel of Terry peyser Blynn, Esquire, 1516 Second Avenue, York,
Pennsylvania, 17403 as her attorney.
The Father has been advised of his right to receive
independent legal advice from counsel of his selection in order to
be fully informed as to his or her legal rights and obligations,
and to have an attorney review this stipulation and Proposed Order.
Father has had this document read to him in his native language,
Vietnamese.
However, Father has refused such representation and has chosen
to refuse to confer with counsel. Accordingly, all parties
acknowledge and accept that this Agreement is, under the
circumstances, fair and equitable, and it is being entered into
freely and voluntarily after having received such advice and with
such knowledge, and that execution of this Agreement is not a
.
result of any duress or undue influence and that it is not the
result of any collusion or improper or legal agreement or
agreements.
7. At all times the parties shall encourage and foster in
the child sincere respect and affection for both the Father, Ban
'1'a, and Patricia and William Guy, and the parties shall not hamper
the natural development of the child's love and respect for the
either of the parties.
Each party shall keep the other party
advised as to any serious illness or any major development with
respect to the child.
8. This Stipulation and subsequent Order of Court shall
continue in full force and effect until further Order of Court and
lor amended agreement in writing between the parties.
l7. The parties hereby waive their right to present this
stipulation in open court or to have their case heard by the Court
'1)'- ~
, ESQUIRE
')..2./q,-
a..~ 'a,_____ 7:,~~..v
WILLIAM '1'. GUY ur
j)rrt':,';'A tl. &1'1
PATRICIA A. GUY (
,
ESQUIRE
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RECEIPT FOR PAYMENT
===================
Cumberland County Prothonotary's Office
Carlisle, Pa 17013
Receipt Date 01/e4/96
Receipt No.
3417:5
GUY WILLIAM T E:T AL (Va> TA BAN
Case Number 1996-0035&
Received of
PD ATTY TERRY PEYSER BLYNN
Total Paid $1!1!1!1!1!1!1!45.51!1 PYMT/CHECK
No. 14ee
T'l'ansaction Desc'l'iption
CUSTODY AGMT
TAX ON AGMT
SETTLEMENT
.TCP FEE
Distribution Of Payment ----------------------------
Payment Amount
35.00
.50
5.00
5.00
CUMBERLAND CO GENERAL FUND
BUREAU OF RECEIPTS AND CONTROL
CUMBERLAND CO GENERAL FUND
BUREAU OF RECEIPTS AND CONTROL
45.50
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2 L 1996'tf-
IN THE COURT OF COIOlON PLEAS OF CUMBERLAND COUNTY
WILLIAM T. GUY
and PATRICIA A. GUY,
Plaintiffs
v.
.
.
.
No. 96-356 CIVIL TERM
BAN TA,
CIVIL ACTION-LAW
IN CUS'l'ODY
Defendant
ORDBR OF COURT
AND NOW, TO WIT,
this d.- 2.-.{
,
YrYlc~
day of
1996, it is hereby ORDERED AND DECREED that the attached
Stipulation for Custody is made an Order of this Court and said
Stipulation
an Order of
is adopted
"
the Court.
in its entirety and incorporated herein as
BY THE COURT:
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IN THB COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
WILLIAM '1'. GUY
and PATRICIA A. GUY,
Plaintiffs
v.
No. 96-356 CIVIL TERM
CIVIL ACTION-LAW
IN CUSTODY
BAN TA,
Defendant
AMENDBD STIPULATION FOR CUSTODY
AND NOW, this ~ day of .lUul'i'l , 1996, the
parties, having reached an agreement with regard to the best
interest of the subject minor child, KIM '1'A, born November 6, 1982,
do hereby agree and stipulate as follows:
1. primary legal and physical custody of the subject child
shall be with William T. and Patricia A. Guy, 333 Evergreen Street,
New Cumberland, PA 17070. There are no other individuals residing
in the Guy household.
2. The Defendant is the child's natural father, Ban Ta, 2258
Berryhill Road, HarriSburg, PA 17104 (hereinafter referred to as
"Father").
3. The reason for this change in custody is that Father has
many health problems which prevent him from working, and has been
in and out of the hospital since his arrival in this country in
June of 1995. The disability benefits Father receives is
inadequate to support him and his daughter.
Father's grown son lives with him, but is not available to
care for Kim Ta's needs. Father wishes to permit this arrangement
as he believes it is best for his daughter to live with the Guys
until she graduates from high school.
4. The natural mother of Kim Ta, BanTa's wife, Doan '1'hi
'1'hua, is still residing in Vietnam with the rest of the Ta family.
Ban Ta has spoken to his wife about this custody arrangement and
Father states that Mother agrees that this arrangement is in her
daughter's best interest. Kim '1'a also spoke to her mother
regarding this custody arrangement, and given father's inability to
care for her because of his illness, mother agrees that it is best
for Kim to stay with the Guys until graduation. Kim Ta further
states that her mother has no expectation that she will ever be
able to leave Vietnam and come to the United states, and hopes that
Kim Ta will be able to go to vietnam after high school graduation
to visit her mother.
5. BanTa and Kim's brother have had to relocate to
Harrisburg because the flood destroyed their home. Kim has been
living with the GUYs since December, 1995. Since September, 1995,
Kim '1'a has been attending the Middle School where Patricia GUY is
a school secretary. The parties agree that it is in Kim '1'a's best
interest to atay with the Guys so that she will not have to make
another adjustment to a new school in a new environment, and so
that Kim Ta will have the continuing care and guidance of the GUYs
to help her with what has been a difficult adjustment to living in
a foreign country.
6. Father shall have liberal rights of partial physical
custody as the parties may mutually agree. The parties agree that
day to day decisions of a routine nature, including but not limited
to bed time, homework, day-to-day social activities, customary for
the child's age and maturity shall be made by the GUYs.
7. The parties agree that if either of them move from the
Harrisburg-carlisle area, notice in writing shall be given to the
other party at least ninety (90) days in advance of said move.
8. The parties agree to submit to the Court of Common Pleas
of Cumberland County, Pennsylvania, a Consent Order of Court for
custody and partial custody in a form identical to that attached
hereto, provisions of which are hereby incorporated by reference in
this stipulation.
For this purpose, the parties hereby submit themselves to
the continuing jurisdiction of the Court of Common Pleas of
Cumberland county, pennsyl vania, which court shall have
jurisdiction over all matters relating to the custody of the minor
child regardless of the residence or domicile of the parties or the
child.
9. The Guys have employed and have had the beneU t of
counsel of Terry Peyser Blynn, Esquire, 1516 Second Avenue, York,
Pennsylvania, 17403 as her attorney.
The Father has been advised of his right to receive
independent legal advice from counsel of his selection in order to
be fully informed as to his or her legal rights and obligations,
and to have an attorney review this Stipulation and Proposed Order.
Father has refused such representation and has chosen to refuse to
confer with counsel.
However, Father has had this document read to him in his
native language, Vietnamese. Accordingly, all parties acknowledge
and accept that this Agreement is, under the circumstances, fair
and equitable, and it is being entered into freely and voluntarily
after having received such advice and with such knowledge, and that
execution of this Agreement is not a result of any duress or undue
influence and that it is not the result of any collusion or
improper or legal agreement or agreements.
10. At all times the parties shall encourage and foster in
the child sincere respect and affection for both the Father, Ban
Ta, and Patricia and William GUY, and the parties shall not hamper
the natural development of the child's love and respect for the
either of the parties. Each party shall keep the other party
advised as to any serious illness or any major development with
respect to the child.
11. This Stipulation and subsequent Order of Court shall
continue in full force and effect until further Order of Court and
lor amended agreement in writing between the parties.
-...-.
12. The parties hereby waive thtlir right to present this
stipulation in open court or to have their case heard by the Court
at this time.
/
~~~"
WITNESS
IUA IJ - HCJAtJ U- _ f.Xrl.irE~
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WILLIAM T. GUY
'.Prrlh~ ,': t7. ) Q. l:1u (f
PATRICIA A. GUY
I~ P. .. uC.-
BAfr'1'A'-" "
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