HomeMy WebLinkAbout96-02923
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IN THE COURT OF COMMON PLEAS FOR
CUMBERLAND COUNTY, PENNSYLVANIA
KIMBERLY H. SWARTZ, CIVIL ACTION - LAW
PETITIONER
V. NO. 96- .J. 'lJJ CIVIL TERM
JOHN E. GSELL, III,
RESPONDENT CUSTODY
,,f~
THIS STIPULATION AND AGREEMENT is made this 0 day of
May, 1996, by llnd between KIMBERLY M. SWARTZ, of 247 Carlisle
Road, Newville, PA, hereinafter referred to as "PETITION~R," and
JOHN E. GSELL, III, of 1026 Centerville Road, Newville, PA,
hereinafter referred to as "RESPONDENT."
1. PETITIONER and RESPONDENT are the natural parents of
GAGE EDWARD SWARTZ, born September 1, 1995.
2. PETITIONER and RESPONDENT were not married at the time
of the hirth of the child, nor at any time subsequent thereto.
3. With the exception of this Bction, neither party has
participated as a party in other litigation concerning the
custody of the child in this or any other court.
4. None of the parties
proceeding concerning the child
outside this Commonwealth.
has information of a custody
pending in a court within or
5. None of the parties knows of any person
the proceedin~s who has physical custody of the
to have cuatody 01' visitation rights with respect
not a pprty to
child or claims
to the child.
6. Since birth, the child has resided with
persons and at the following addresses:
the follOWing
MME
Al2.I1.R.~
DAtE
Kimberly M. Swartz
247 Carlisle Road
Newville, PA 17241
September I,
1995 to pre.ent
7. The parties have reached an agreement with respect to
the custody of their minor child and desire to reduce and
incorporate their agreement to an order of court.
"
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8. The parties agree that the terms of their agreement are
in the best interest of the child.
9. The parties further agree that, in procuring thla
Agreement, there has been no fraud. concealment, overreaching.
c:oercion or other unfair dealing on the part of the other.
NOW, THEREFORE, the parties Intend to be legally bound and
waiving their right to be present when this Agreement and Order
are presented and executed. hereby stipulate and agree that the
Court may enter the following Order of Court in the above
capt loned case:
ORDER OF COURT
NOW,
consideration of the
it is hereby ordered
.
within Stipulation and
as follows:
1996, upon
Agreement,
1. PETITIONER shall have legal custody of the
minor child, GAGE EDWARD SWARTZ.
2, PETITIONER shall exercise primary physical
custody of said minor child.
3. RESPONDENT shall exercise visitation as can be
agreed by the parties. PETITIONER shall not unreason-
ably withhold her consent to visitation. as the purpose
of this Agreement is to allow each party to maintain
strong and meaningful relationsh\ps with the child.
4. On holidays, RESPONDENT shall exercise
visitation as can be agreed between the parties.
5. Neithe~ party shall do anything which may
estrange the child from the other parent, or injure the
opinion of the child as to the other parent or which
may hamper the free and natural development of the
child's love or respect for the other parent.
By the Court.
J. '
'".
"---"'-"-'-
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IN WITNESS WHEREOF. the partiu hereto, intendin. to be
le.ally bound hereby, do execute this Stipulation and Alreement.
WITNESS:
'-- k:...~ Q c;- L.l~.u.t.-
ItkUbtl-P'-IJ
d.,J~ /11 d1h@
jl~ y . .SWARTZ
~ ~' .J;f
";.)OHN E. GSELL, II I
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