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HomeMy WebLinkAbout96-02330 /I-If' ~7 &d l~jJ //I;Ji,t 'I. t't'4 {1~ I/-I?/.~? '71~ ft~/ ~' J1f a~u<k.l 'I , , , \ ' , . , I' , ': I II ,\ ~ I !. o . i ~ ' If. , II \ !. . !. II- . " , It ", , " RUTH M. BROWN, Plaintiff VS. DAVID A. BROWN, Defendant IN 1'Im couwr Qt' COHHON 1'1,~;M; CUHDf:RI.AND COUNTY. PENNSYLVANIA CIVI L DIVISION NO. 96-2330 CIVIL TERH PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record. together with the following information to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under 533011c) 3301Idlll) of the Divorce Code. IStrike out inapplicable section). 2. Date and manner of service of the complaint: June 6, 1996; certified mail, restricted delivery 3. Complete either paragr"ph la) o=- Ib). la) Date of execution of Lhe affidavit of consent required hy S3JOllc) of the Divorce Code: by plainLiff 11/17/97 hy de fendan t --1W.'1.L~__________ __' Iblll) Date of execution of the affidavit required by SJJ01(d) of the Divorce Code: : (7.) Date of filing and service of the plaintiff's affidavit upon the ri!spondent: 4. Related Claims pending: none S. Complete either I a) or (b). la) Date .and manner of service, of ti,e notice of intention Lo file praecipe to transmi t rccord. a copy 0 f which in attached: Ib) Date plaintiff's Waiver of Not.ice in SJ30l(c) Divorce was fi led with the Prothonctary: ______l'!.<-,,'e.'7'bu. 11. Iqq~ Date defendant'n Waivllr of Notice in SJ30l(c) Divorce was filed with the Prothonotary: __.l-:!. GVlYT1h~, 17. /qq) . , - / /~,\ ~. -C::---/ "J ...~' - ... ........ ^lt~l:'; f(}'~- tJil~inti HI( ~~~/WIA~k) Johnn J. Deily, Esqllire . " -, . \ \ g ,,', 'J ~, ",.. '"TJlr; " ~tH . f', ~~" .,:") lJj .r .a.I' I,S ~(:) \. ~,. .,;\ :P.p , . . !(l~ (;:) )111 p~; " :" t.' ~ ~.l , ,p '0;, .. ; Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVAN IA RUTH M. BROWN, v. NO. 96-.:J :J~(l CIVIL TERM DAVID A. BROWN, Defendant CIVIL ACTION - LAW IN DIVORCE COMPLAINT UNDER SECTION 33011cl OR 33011dl OF THE DIVORCE COUE L Plaintiff is Ruth M. Brown, who currently resides at 607 Fairview Road, Carlisle, Cumberland County, pennsylvania. 2. Defendant is David A. Brown, who currently resides at 607 Fairview Road, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 16, 1966 in Carlisle, Cumberland County, Pennsylvania. S. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to SAlOIS, GUIDO, request that the Court require the parties to participate in SHUFF '" MASLAND counseling. Having been so advised Plaintiff does not desire the l6 w. Hllh S..., C."i.Ie, PA Court to order counseling. 7. The marriage is irretrievably broken. ... .. -,- [' , " I' t t. (,'.' .. "'1 I ) , .J ) ., ~ . - " ..., ... a UI " ~ " . ., c " ~ (.II ", \ SAIDIS, GUIDO, SHUFF ole MASLAND 26 W. Hilh SlI'ee' Cllhlle. PA (2) Except as herein otherwiae provided. each party hereby releases the othflr from any and all claims, or demands up to the date of execution hereof, (3) In the event that either party contracted or incurred any debts or liabilities since the date of separation in June 1, 1996, the party who incurred said debt or liability shall be responsible for the payment thel'eof regardless of the name in which the account may have been charged. The parties acknowledge and agree that they have no other outstanding joint or marital debts or obligations incurred prior to the signing of this Agreement except as follows: A. Dauphin Deposit MasterCard in the approximate amount of $1,200,00 which shall be assumed by Wife. B, Chemical Bank VISA shall be assumed by Husband. Each party agrees to pay the outstanding joint or marital debts set forth herein and further agrees to indemnify and save harmless the other from any and all claims and demands made against either of them by reason of such debts or obligations. (4) Each party relinquishes any right, title and interest he or she may have to any and all motor vehicles currently in possession of the other party. Each party shall execute any documents necessary to have said vehicles properly registered in the other party's name with the Penneylvania Department of Transportation, 2 (5) The parties hereto mutually agree that they have effected a satisfactory division of the furniture, household furnishings, appliances, tools and other household personal property between them, and they mutually agree that each party shall from and after the date hereof be the sole and separate owner of all such property presently in his or her possession whether said property was heretofore owned jointly or individually by the parties hereto, This agreement shall have the effect of an assignment or bill of sale from each party to the other for such property as may be in the individual possession of each of the parties hereto. (6) Wif~ shall pay to Husband the sum of $2,000.00 upon the signing of this Agreement. Further, Wife shall, and does hereby, forgive and discharge any and all Bums owed to her by Husband pursuant to a certain Note dated May 6, 1996. a copy of which is attached hereto as Exhibit "A". Further Wife agrees to forgive back support in the amount of $692.28. and agrees to pay the sum of $1.036.42 to Husband for the benefit of the parties' child support obligation, which sum shall be returned by Husband payable to the Cumberland County Office of Domestic Relations. SAIDIS, GUIDO, SHUFF " MASLAND 26 W. Hllh Smel Culi.le,P'" (7) Except as otherwise provided herein. each party hereby relinquishes any right, title or interest he or 'lhe may have in or to any intangible personal property currently titled in the name of or in the possession of the other party, 3 - i I~ I- I Ii I" Ii, I', II , I ','I' II' Ii ;/. "" 1\,1. ilf I.' including, but not limited to, stocks, bonds. insurance, bank accounts and retirement accounts, (8) The parties agree that legal custody of their minor children, Edward W, Brown, Julianna M, Brown and Christina R, Brown, shall be joint. with both parties having the right to share in major parenting decisions involving both privileges and disciplines or infractions. such as poor and failing grades, a suspension from school. sexual matters or matters involving violence, matters involving the authorities or school or organizational authorities as well as privileges of a significant nature such as driving. dating, unchaperoned events or unchaperoned significant time periods, additions of major activities and major expenditures. The exchange of any and all information invoLving the nlatters described herein shall be made in a timely fashion, Wife shall have primary physical custody of the children subject to Husband I s partial physical custody at the following times: (a) Every other weekend from Friday after work bctween 6:30 p,m, and 7:30 p,m, until Sunday at 6:00 p.m. or 6:30 p.m, while the children are in school, and 9:30 or 9:00 p,m. when SAIDIS, GUIDO, SHUFF '" MASLAND 26 W. Hi,h Stnel Culi,le, PA the children are out of school or during school breaks. When Wife has the children on the first weekend of the month, Husband has one of the kids or the two girls on the third weekend, When Husband has the kids on the first weekend of the month, he would have one of the children or the two girls on 4 ! I ! i. Ii i./: I. t" Ii \ I I I Ii I I I" ~ f the fourth weekend, When Wife has the kids on the first weekend of the month, and there are five weekends in the month. Husband shall have one of the children or the two girls on the fifth weekend, which child/children go for visitation shall be determined as mutually agreed upon by the parties; (b) Two evenings per week when he does not have all of the children on the following weekend, and one evening per week when he does have all of the children for a visitation weekend. from after work until 6:00 p.m, while the children are in school. and 9: 30 or 9: 00 p, m, while the childr'en are out of school or during school breaks: (c) Christmas shall be split into two periods: (i) . Christmas Eve from 6:00 p,m. until Christmas Day at 3:00 p,m. , and (it) , Christmas Day at 3:00 p.m. unt il December 26 at 5:00 p.m, (iii) Christmas vacation after 5:00 p.m.. December 26 shall be divided into two equal amounts of time each year in periods of as little as one-half days. determined no later than one month prior to Christmas. as mutually agreed upon by the parties and as work schedules will dictate and permit an SAlOIS, GUIDO, SHUFF" MASLAND 26 W. Hilh S...., CIIII.le, PA appropriate schedule of this division of time. These periods shall alternate. with Husband receiving Part (il for 1997 and subsequent odd-numbered years and Part (ii) for 1998 and subsequent even-numbered years, 5 - I I \ I , f' t ' " " , '.,' 'i; ,;!" (d) Thanksgiving is to be divided into two sectionsl From 6100 p.m, on the night before ThanksgivIng until 2:00 p,m, on Thanksgiving Day, and from 2100 p.m, on Thanksgiving Day unt 11 the following morning at '7IJO a,m, or 6:00 a.m. Husband ,-I~~~ shall have the first period in odd numbered years/ and the~ :\=>f-' have the second period in even numbered years. .-, ~ (e) Easter is to be divided into two sections: From 6:00 p,m, on the night before Easter until 2:00 p,m. on Easter Day. and from 2:00 p.m. on Easter Day until the following morning at 7:30 a,m. or 6:00 a.m, Husband shall have the first period in IN~~J odd numbered years. and the 1tJ:'n! have the second period in even numbered years, yr?- (fl Father's Day shall re the Saturday before Father's Day between 6:00 and 7:00 p.m.. to Father's Day evening between 6:00 and 9:00 p.m, (Provided. however, that wife shall always have the children on Mother's Day, any other visitation scheduled hereunder notwithstanding) , (g) The option of taking 6 non-consecutive weeks during the year, which may be expended in periods of as little as o~e- SAIDIS, GUIDO, SHUFF '" MASLAND 26 W. Hlah 5lml Cull,I., PA half days defined as from 5:00 p,m. until 9:00 p.m. or the following morning as determined by the Father, provided that he gives Wife at laast 10 days notice of his intention to exercise such visitation for periods exceeding three days, one week notice for periods of between three and two days. and 24 hour notice for single days and evenings. These periods are not 6 , , SAIDIS, GUIDO. SHUFF" MASLAND 26 W. Hiah Slffi:1 Culi,I" PA accounted as expended during other visitation periods outlined herein, but rather are in addition to those periods. (h) Spring vacation shall be divided into two equal time frames in periods of as little as one-half days determined by no later than one month prior to spring break, as determined by the parties and as work schedules would dictate and permit an appropriate schedule of this division of time, (i) Such other times as the parties may from time to time agree, taking into account state holidays, which shall not be counted in the six weeks visitation as stated previously. (9) The parties agree that the support Order entered at No, 611 S 96. D,R, # 25.570 shall be reduced from $500.00 per month to $430,00 per month, effective upon the signing of this Agreement, and sh:111 last for a period of two years, The parties further agree that in the event of a material change in circumstances of either party, or a change in the custody arrangements set forth herein. the amount of support shall be subject to an appropriate adjustment by agreement only in the event it will reduce the amount of child support below the $430.00 per month set forth herein. (10) Husband shall not pay to Wife nor Wife to Husband any sum whatsoever as alimony. alimony pendente lite, or for his or her support or maintenance. (11) Each party is now represented by counsel of his and her own choice. and eacn shall pay his or her own attorney for 7 all legal services renden:d or to be rendered on his or her behalf . (12) Neither party shall contract or incur any debt or liability for which the other party or his or her property or estate might be responsible and shall indemnify and save the other party harmless from any and all claims or demands made against him or her by reason of debts or obligations incurred by the other party, (13) Each of the parties shall from time to time, at the request of the other, execute. acknowledge and deliver to the other party any and all further inst.ruments that may be reasonably required to give full force and effect to the provision of this Agreement. (14) The parties do hereby warrant. represent, acknowledge " , - and agree that each is fully and completely informed of, and is familiar with. the wealth, real and personal property, estate and assets. earnings and income of the other and that each has made a full and complete disclosure to the other of his and her entire assets and liabilities and any further enumeration or statemenc thereof in this Agreement is specifically waived, (15) Husband and Wi fe acknowledge that each of them has read and understand his and her rights and responsibilities SAlOIS, GUIDO, SHUFF ... MASLAND 26 W. Hish S""'" CarlimJe, PA under this Agreement and that they have executed this Agreement under no compulsion to do so but as a voluntary act. (16) It is further specifically understood and agreed by and between the parties hereto that each party accepts the 6 acquired, including but not limited to all, rights or claimsl (1) to take againAt the other's will, (2) under the laws of intestacy; (3) to a fam.i1y exemption or similar allowance, and (4) all other rights or authority to participate or intervene in a deceased spouse's estate in any way, whether arising under the laws of Pennsylvania or any other cOuntry, territory, state or political subdivision, F. All rights or claims to any accounting; G. All rights, claims, demands, liabilities and obligations arising out of or in connection with the marital relationship or the joint Ownership of property, whether real, personal or mixed; H, All rights, claims, demands, liabilities and obligations arising under the provisions of the Pennsylvania Divorce Code, Act 26 of 1980, as the same may be amended from time to time, and under the prOVisions of SAIDIS, GUIDO, SHUFF" MASLAND 26 W, Hllh Slteel Carll.Je, PA territory or political SUbdiVision; any similar statute enacted by any other country, state, I. All rights, claims, demands, liabilities and obligations each party now has, or may hereafter have, against or with respect to the other, 10 SAlOIS, GUIDO, SHUFF .. MASl.AND 16 W III.h Sor... Cull, I" PA (181 This Agreement shall be construed under the law of the Commonweal th of I'ennsyl vania, If any provision of this Agreement is determined to be invalid or unenforceable, all other provisions shall continue in full force and effect. (19) In the event that either of the parties shall recover a final judgment or decree of absolute divorce against the other in a court of competent jurisdiction, the provisions of this Agreement may be incorporated by reference or in substance but shall not be merged into such judgment or decree and this Agreement sha 11 surv i ve any such final judgment or decree of absolute divorce and shall be entirely independent thereof. (20) In the event that either party breaches any provision of this Agl'eement, and the other party retains counsel to aHsist in enforcing the terms thereof, the parties hereby agree that the breaching party will pay all attorney's fees, court costs and p.xpenses incurred by the other party in enforcing the Agreement, (211 This Agreement constitutes the entire understanding between the parties and there are no covenants, conditions, representations, or agreements, oral or written, of any nature whatsoever, other than those herein contained, (22) This Agreement shall bind the parties hereto, their respective heirs, executors and assigns, 11 RUTH M, BROWN, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 96, 2 330 Plaintiff v, DAVID A. BROWN, Defendant TN DIVORCE PLAINTIE"~ AFFIDAVIT OF CONS~NT AND WAIVER OF NOTICE QF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (cl ..QE... THE DIVORCE CODE 1. A Complaint in divorce under Section 3301 (c) of the Divorce Code was filed on 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3, I consent to the entry of a final dp-cree of divorce without notice, 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them befor~ a divorce is granted, 5, I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 16 Pa, C.S. Section 4904 relating to unsworn falsification to authorities. DATED:--JJ~J1~'1 ~~~')~~laintiff SAIDIS, GUIDO, SHUFF .. MASLAND 26 w. Hl,h 5'"," Cull,I., PA , " ':' , '11 ;~ ,. RUTH M, BROWN Plainliff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, nVIL ACTION - LAW DAVID A, BROWN, Defendant NO. 96-2330 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 30, 1996, 2. The marriage of Plaintiff and Delendant is irretrievably broken and ninety (90) days have elapsed from the date of tiling the Complain!. 3, I consent to the entry of a tinal decree of divorce after service of notice of intention to request enlry of the decree. I verify that the statements made in this Affidavit are true and correct. I understand that false slatements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904, relating to unsworn falsification to authorities. Date: t2~j~... ,-}.f /117 ~,- /~. tt:j~'.-L.' -' David A. Brown, Defendant -, " , 1 P .0 0 -I '" .~ Ol'!: ! "'0 f.T~ ':-:':) .,IIi!1 (1)(1 : .,~ :(.;[1 '1123 (i1..t~ -.J 'I JI? ~~:C , ?'ir J'!.fl F'e -. ~~ .~(.-, - J,aoe - '.) ~~ .. Ji' ~ ~I ~ '" " RUTH M, BROWN Plaintiff IN TilE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION. LAW DAVID A, BROWN, Defendant NO, 96.2330 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE lJNDER II 3301(c) OF TilE DIVORCE CODE \, \ consenlto the entry of a tinal decree of divorce without notice. 2. (understand that I may lose rights concerning alimony, division of propeny, lawyer's fees or expen.,es if ( do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Coun and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand that false stalemenlS herein are made subject to the penalties of 18 Pa. C.S. ~4904. relaling to unsworn falsification to authorities. Date: (!(~J,..;- -.2.~ /!Y/'1 -'1)!v;i ^~ B~-:.;.-geie~"'" --------- n ~ 0 li.: '11 ,,;!!: ,1 "T:1f" q 'l-.:n Ell i. '- ,~ ' . ..)10" -.j ";, 1...' ,I "6 ',. . ~:i ~# "1 ~.:(:.: ~ i. _\ . )., '~(' ... ..f') :!Zf, .;: r~n ;.'.~..... .. ~:; .~ 'JI ~i -. (I'> ..... " , ' . , P- '0 C.:J <I' '11 " ';RiD r .;1 ;:1 [l..f"'i ,.,:~ ~~' -. 0', , I ~ . r;, ~_!': J ~f." 3~ S::,." ';It> " '-" ~-~t - '~n .,.. ~; J:;' ?-! , , , , c, \ltn., .hand\d ~ '1oru\brl)1m\rvnrOllfl. Itoe RUTH M, BROWN Respondelll/Plainlifl' IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - LAW DAVID A, BROWN. PelitonerlDefendant NO. 96-2330 CIVIL TERM IN DIVORCE COMPLAINT FOR CUSTODY I, The PetitionerlDefendant is David A, Brown, residing at 159 South Pill Street, Apartment 4. Cumberland COUnly, Pennsylvania 17013. 2. The Respondenl/Plainliff is Ruth M. Brown, residing at 803 Fairview Road. Carlisle. Cumberland Counly. Pennsyvlania 17013. 3. Petitioner seeks parlial cuslody of the following children: NAME RESlWili.C.E IlQB Am:. 803 Fairview Road 5/4/83 14 yrs 6 mos Carlisle, PAl 70 13 803 Fairview Road 12/20/88 8 yrs 10 mos ' Carlisle, PA 17013 803 Fairview Road 1/4/91 6 yrs 10 mos Carlisle. PA 17013 Edward W. Brown Juliana M. Brown Christina R. Brown The children were not born out .11' wedlock. I \ The children arc presenlly in Ihe custody of Respondenl/Plaintiff, During their lives, the children have resided with the following persons and at the following addresses: . .--.-........"'....' , <',ld.t,\.h.re.t\,tll',;I(lI\!JI')WII\Cll.tc0l'fl4ur: ~ME ADDRESS DATES Ruth M. Brown and Bill Hess Ruth M. Brown 803 Fairvlew Road Carlisle. PA 17013 807 Fairview Road Carlisle. PA 17013 October 1996 to present May 28, 1996 to October 1996 Ruth M. Brown David A. Brown 807 Fairview Road Carlisle. PA 17013 May 18, 1988 to May 28. 1996 The mother of the children is Ruth M. Brown, currently residing at 803 Fairview Road. Carlisle, PA. She is married. The father of the children is David A. Brown, currently residing at 159 South Pitt Street, Apt.4. Carlisle, PA. He is married. 4, The relationship of the Respondent/Plaintiff to the children is that of mother. The Respondent/Plaintiff currently resides with the following persons: William Hess 5. The relationship of the PetitionerlDefendant to the children is that of father, The Petitioner/Defendant currently resides with the following persons: None 6. Petitioner/Defendant 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. PetitionerlDefendant has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. PctitionerlDehmdant does nol know of a person not a party to the proceedings who has physical custody of the children or claims 10 have custody or visitation rights with respect to the children, , r 7. The best interest and permanent welfare of the children will be served by granting the relief requested for the following reasons: -l. U ~ .~ ~ I t '. ( , -d J? .' " ~ r) '% ' . \' I 8 , ,., I I ,. d ~ , ~ , ~ ~ rJL , v z o cn~ll ~ .:Lil ~ ~ g~~~~ 011>0 .M cn~ll.~" ;t '" il' r:" t&l~~ 0 ~<~ 'i ., \'1\....,,\'1/ ".> \J' .."', ,. "1.. , ., , ." . ' I,:~,j 'I ': '.In"" , . I ,) i~~ q I!,I :~ I'.U:~ Lo /U'/~.I.,I " IJ ~':'i :1.. I.. l, J .-;6\ I <: I \d.t.\lh"e4\d~VQJr:I\b,own\L'UItIldV It L Father shall have one of the children or the two girls on the fifth weekend, Which " child/children go for visitation shall be determined as mUlUally agreed upon hy the parties; Ib) Two evenings per week when he does not h;lVe all of Ihe children on the following weekend. and onc evening per week when he does have all of the children for a visitation lhe following weekend, from afler work until 8:00 p.m. while the children are in school, and 9:30 or 9:00 p.m. while the children are out of school or during school breaks; (c) Christmas shall be split inlo two periods: (i) Christmas Eve from 6:00 p.m. until Christmas Day at 3:00 p.m., and I I (ii) Christmas Day at 3:00 p.m. until December 26 at 5:00 p,m. i I I I (Hi) Christmas vacation after 5:00 p.m., December 26 shall be divided into two equal amounts of time each year in periods of as lillle as one-half days, determined no later than one month priol' to Christmas, as mutually agreed upon by the parties and as I I ( ~ I' , ., , ~ . I 1 , work schedules will dictate and permit an appropriate s~hedule of this division of time. These periods shall alternate, with Father receiving Part (i) for 1997 and subsequent odd-numbered years and Part (ii) for 1998 and subsequent even-numbered years, (d) Thanksgiving is to be divided into two sections: From 6:00 p.m, on the , . night before Thanksgiving until 2:00 p,m. on Thanksgiving Day. and from 2:00 p.m. on Thanksgiving Day until the following morning at 7:30 a.m. or 8:00 a.m. Father ~hall , ,,'I have the tirst period in odd numbered ycars, and the Father have tile second period in I"~ , is even numbered years, c, \dlt.\.hUltlS\d1voro:.\brll"n\O:Il.tQdy nt L (e) Easter IS to be divided into two sections: From 6:00 p,m. on the night before Easter until 2:00 p,m. on Easter Day, and from 2:00 p.m, on Easter Day until the following morning at 7:30 a,m, or 8:00 a.m. "'ather shall have the first period in odd numbered years, and the Father have the second period in even numhered years. (I) Each Father's Day which shall he from the Saturday he fore Father's Day between 6:00 p.m. and 7:00 p.m.. 10 Father's Day evening between 8:00 and 9:00 p.m, (Provided, however, that Mother shall always have the children on Mother's Day, any other visitation scheduled hereunder notwithstanding). (g) The option of taking 6 non-consecutive weeks (42 days) during the year, which may he expended in periods of as Iillle as one-half day defined as from 5:00 p.m. until 9:00 p.m, or the following morning as determined hy the Father, provided that he gives Mother at least 30 days notice of his intention to exercise such visitation for periods exceeding three days, one week notice for periods of between three and two days, and 24 hour notice for single days and evenings. These periods are not counted as expended during other visitation periods outlined herein, hut rather are in addition to those periods. (h) Spring vacation shall be divided into two equal time frames in periods of as little as one-half day determined by no later than one month prior to spring break. as determined by the parties and as work schedules would dictate and permit an appropriate schedule of this division of time, (i) Such other times as the parties may from time to time agree, taking into account state holidays, which shall not be counted in the six weeks visitation as ~taled previously in (g). -J> t: I \d'U"h".~\d \ 'IIcru\btQWJ\\CU.lQdV' It L RUTH M, BROWN Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUN'fY, PENNSYLV ANIA CiVIL ACflON - LAW v, NO. 96-2330 CIVIL TERM IN DIVORCE DAVID A., BROWN. Defendant P1a'~'ff, ,"'b M, ._n, "'re.he' ref"'''''' " M....', .01 ",f,oI'~, ..',. ., STIPllLA.T10N R"~GA.RDlNG ClJSTOOY-VlSITA.TION _n, ",re"" ref"''''' " " ....." _b1 ..~< " '''' 'M" b, '''' ",,,""b. c,urt ,f ,.. f,lIoWin. "n" ,. . Cuurt 0",,' ,,1I.,u. ""., .01 ,,,... ",,01, ".b" .01 ",_\bil'"'' ,. "~,'"" " ,.. ,...,' ",,,,,,hi"re' ..w'" W. Browu, b"" Mo, 4, ,,83, .01 Jut"'" M. BroWU, "'.. D,,,rohe' 20, "",, .ol Cb"U'" R. BroWO, "''" 1."".,4, \991, -,...., referenced as Children: f\ I Sb.red le.'\ ""ol, of ...... W. BroWO, I"'" M. B'''''" .01 C..~""' R BNWU " ,ou,,",,\..e' by '''' ." of ",,_, " ,,84, P .S. 1'001, " WI.. i' .....dol " Mother and Father. 12) Ph,,\,,1 ",,01, 0"" Chi"ro'. FAw," W. BroWO, "II... M. B"'w' "" Cb""'" R. Brown, " .W."'" " M""'" "bj'"" ,.rtl.\ """,, b,.- u foil"''' '" E'''' ~"" w"",ol horo .,"., ...' w"'. ",,- 6,30 p..', ..... 7,'" ,.", ,Mil Suud., .. ,.00 p. ro M ,.30 ,.M. whi. "" ,hild'" .R 1"'bOO\, ... 9,30" ,.00 ,.ro. w'" ,b. ,hi"'" '" 0" of "boo\ '" ."".. ~....I b_. Wl<n -... .he ,hi"'" "" '''' ""' we<,"", '''''' ",Mb, ."", ... ""' of .. ,bi_ .. ... twO ,i'\' o. ,.. ,hi" _,,,,d. When ..,,,,, b" "" ,hi"re' "" '''' .." ........ of" r.', \,'.l.\.h,lt.<t\,ll.vote.\bl OWI1Il.".t <l4y ~ll month, he wuuld have um: of lhe children or the twu girls on the lilurlh weekend. When Mother has the kids un the lirst weekend of the munth and there are live weekends In the month, Father shall have one uf the children or the twu girls on the liflh weekend. Which child/children go for visitation shall he determined as mutually agreed upun hy Mother and Father; (h) Two evenings per week when he does not have all of the children on the following weekend, and one evening per week when he does have all of the children for a visilation the following weekend, from after work until 8:00 p.m. while the children are in school, and 9:30 or 9:00 p.m. while tht1 children are out of school or during school breaks; (c) Christmas shall be split into two periods: (i) Christmas Eve from 6:00 p.m, until Christmas Day at 3:00 p.m., and (ii) Christmas Day at 3:00 p.m. until December 26 at 5:00 p.m. (iii) Christmas vacation after 5:00 p.m" December 26 shall be divided into two equal amounts of time each year in periods of as little as one-half days, determined no later than one month prior to Christmas, as mutually agreed upon by the parties and as work schedules will dictate and permit an appropriate schedule of this division of time. These periods shall alternate. with Father receiving Part (i) for 1997 and subsequent odd-numbered years and Parl (ii) for 1998 and subsequent even.numbered years. (d) Thanksgiving is to he divided into two seclions: From 6:00 p.m. on the night before Thanksgiving until 2:00 p.m, on ::'~'1ksgiving Day, and from 2:00 p.m, on Thanksgiving Day until the following morning at 7:30 a,m, or 8:00 a.m. Father shall have the first period in odd numbered years, and the Father have the second period in 1.:,\,I.t.'lh.J."',,hv'JrcI\b'Il.t1\Cllltl).ly III even numbered years. (e) Easter is to be divided into two seclions: From 6:00 p,m. on the night before Easter until 2:00 p.m. on Easter Day, and from 2:00 p,m, on Easter Day umilthe following morning at 7:30 a.m, or 8:00 a,m. Father shall have the lirst period in odd numbered years, and the Father have the second period in even numbered years. (I) Each Father's Day which shall he from the Saturday before Father's Day between 6:00 p.m. and 7:00 p.m., 10 Father's Day evening between 8:00 and 9:00 p.m. (Provided, however, that Mother shall always have the children on Mother's Day, any other visitation scheduled hereunder notwithstanding). (g) The option of taking 6 non-consecutive weeks (42 days) during the year, which may be expended in periods of as lillle as one-half day delined as from 5:00 p.m. until 9:00 p.m. or the following morning as determined by the Father, provided that he gives Mother at least 30 days notice of his intention to exercise such visitation for periods exceeding three days, one week notice for periods of between three and two days, and 24 hour notice for single days and evenings. These periods are nOI counted as expended during other visitation periods outlined herein, hut rather are in addition to those periods. f I~ 1\ ,I I, It ," ,\ :1/ ' II I' (h) Spring vacation shall be divided into two equal time frames in periods of as litlle as one-half day determined by no later than one month prior to spring break, as determined by the parties and as work schedules would dictate and permit an appropriate schedule of this division of time. (I) Such other times as the parties may from time to time agree, taking into account state holidays, which shall not be counted in the six weeks visitation as stated " previously in (g). ~~ " " " '" ''{ '- " , - ~ . , .~ , r , .oJ y J I y .- r l ,-.; h (-..- r' z ~ z ;c li '" =j~-~ o f-~~L~ -. >( < _.. <II Q.. .i:o ..N IIJ~ zQ...l/" ~i!;Bf:: I::=j~ ~<l'!: ~ < . . .