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RALPH D. MCNATT AND GRACE R.
MCNATT,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
v.
CIVIL ACTION - LAW
NO. ')f.. /,"'{,1 6,,~;j '-r;,..,
JENNIFER MCNATT BOTTARO,
Defendant
ORDER
AND NOW, this
I (9 'I-
day of April, 1996, it is hereby
ORDERED and DECREED that the Stipulation and Agreell'ent of the
Parties for the Custody of Brian D. McNatt as set forth in the
attached Stipulation and Agreement, be entered as an Order of
Court.
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C' 4 ,10,11 AGREEMENT
THIS AGREEMENT made this y.U, day of April, 1996, by and
between Jennifer McNatt Bottaro, of Dauphin County, Pennsylvania
(hereinafter referred to as "Mother") and Ralph D. McNatt and Grace
R. McNatt, his wife (hereinafter referred to as "Grandparents").
WITNESSETH:
Factual Backqround
1. Jennifer McNatt Bottaro is the mother of Brian D. McNatt.
2. Jennifer McNatt Bottaro resides at 3890 Mark Avenue,
Dauphin County, Harrisburg, Pennsylvania 17110.
3. Brian McNatt is 17 years old, born March 9, 1979. and
attends Cedar Cliff High School.
4. Brian McNatt has been in the West Shore School District
since 1984.
5. Donald E. Bell is the father of Brian D. McNatt.
6. The whereabouts of Donald E. Bell are unknown to Defendant
in that Donald E. Bell has not made contact with Defendant or his
son, Brian McNatt in fourteen years.
7. A custody agreement from May of 1980 exists granting
custody of Brian D. McNatt to Jennifer McNatt (Mother). A copy is
attached and marked Exhibit "A."
8. Ralph D. McNatt and Grace R. McNatt are the maternal
grandparents of Brian D. McNatt.
9. Ralph D. McNatt and Grace R. McNatt reside at 821
Pennsylvania Avenue, Lemoyne, P,mnsyl vania 17043.
10. Brian McNatt t'esides with his Gt'andparents and with his
Mother on a shared basis.
WHEREAS, the pJrties hereto desire to grant custody of Brian
McNatt to the Grandparents so that Brian McNatt may finish school
at Cedar Cliff High school.
NOW THEREFORE, the parties intending to be legally bound
hereby do covenant and agree as follows:
1. Grandparents shall have primary physical custody of Brian
McNatt.
2, Grandparents and Mothet- shall have shared legal custody of
Brian McNatt.
3. Grandparents may make medical decisions on an emergency
basis for Brian McNatt without consulting Mother.
WITNESS I
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Ra pD. McN1ltt
~/il"" Q /dO) 'np7L;"-
Grace R. McNatt
~t!~mcJfdf"1j~
J nHe McNatt Bottaro
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COMMONWEALTH OF PENNSYLVANIA, COUNTY OF
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)SS.
BE IT REMEMBERED, that on
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before me the subscriber personally appeared Ralph D. McNatt and
Grace R. McNatt, his wife, known to me (or satisfactorily proven)
to be the persons whose names are subscribed to the within
Agreement and acknowledged that they executed the same for the
purposes therein contained.
WITNESS my hand and seal the day and year aforesaid.
/
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/lOrAn'" SfAl
STALi l A'cAIi. NOMRY I'URLlC
BOROUmt OF CARLISLE, CUMBERLAND CO PA
MY COMMISSION EXPIRES JUNE Ol. 1991
['dll'),r,.i/,'11'( )SS,
COMMONWEALTH OF PENNSYLVANIA, COUNTY OF
BE IT REMEMBERED, that on
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before me the subscriber personally appeared Jennifer McNatt
Bottaro, known to me (or satisfactorily proven) to be the person
whose name is subscribed to the within Agreement and acknowledged
that she executed the same for the purposes therein contained,
WITNESS my hand and seal the day and year aforesaid.
,j){rt t I 'f, "
Notary Public' /
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NOTARIAL SEAL
STACI LAYERS, /I0TARY PURLlC
BOROUGH OF CARLISlE, CUMBERlAtW CO PA
MY COMMISSION EXPIRES JUNE Ol 1991
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AGREEMENT
THIS AGREEMENT made this day of May,
1980, by and between JENNIFER L, BELL of Cumberl~nd
County, Pennsylvania (hereinafter referred to as "Wife")
and DONALD E. BELL of Cumberland County, Pennsylvania
(hereinafter referred to as "Husband"),
WITNESSETH:
WHEREAS, Husband and Wife were lawfully married
on April 16, 1977; and ..
WHEREAS, one children has been born of this marriage,
Brian E. Bell; and
WHEREAS, Differences have arisen between Husband
and Wife in consequence of which they have been separate and
apart from each otherj and
NOW, THEREFORE, the parties intending to be legally bound
hereby do covenant and agree:
1. Wife shall have custody of the parties' minor child,
Brian E, Bell born on March 19, 1979 subject to reasonable
visitation rights to be exercised by the Husband. It is
agreed that Husband shall give Wife twenty-four hours notice
prior to visitation.
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