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Home My WebLink About96-05254 \. \l , 'It '\L \:J ~ ~ ~ \I ~ t ~ ~ ~ " fO . . , .c..'", -",~{\t~ , AUG 2)1602 MERLE E. MAlTHEWS, JR., PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSVL VANIA CIVIL ACTION - LAW . . V. LISA M. CRAMER, nIkIa, LISA M. CRAIN DEFENDANT NO. 96 - 5254 CIVIL TERM IN CUSTODY . . J. WESLEV OLER, JR. JUDGE AND NOW, this.z.:kl day oL-ll . , <\ ... !i. t the within Stipulated Custody Agreement, IT IS HEREBY ORDERED AND DECREED THAT: l. The parties shall share legal custody of the parties' minor child, Samantha N. Matthews, , 2002, upon consideration of born October 2. 1994. 2. The Father shall have primary physical custody of the parties' minor child. 3. Mother shall be entitled to libcral periods of visitation, IS the parties mutually ape. whic:h. at 1 minimum shall include: I) During the sd1oo1 year OIl a1tcmatin& weekends ccmmencina OIl Fridays .. 7:00 p.m. until Sunday at 7:00 p.m. b) During SI8llmer \'IaIIiOn &om school OIl aItmIatint weeks M~ m Sunday at 5:00 p.m. until the rolkwring Sunday.. S:OO p.m. ... Mocha- h1niaa the lint wen. , -....- c) Mother shall have one period of visitation that may be at the begiMing or end of each school break for Easter and Christmas and shall begin at 9:00 a.m. and end at 6:00 p.m. the next evening. 4. The parties shall alternate custody of the child during the following holidays: Thanksgiving, New Years Day, Fourth of July, Memorial Day and labor Day. These holiday visits shall commence at 6:00 p.rn. the evening before the observed holiday and end at 6:00 pm. on the day of the observed holiday. s. Christmas visitation shall be: divided into two segments: a) SqIum A shall begin at 2:00 p.rn. on December 24'" and end at 2:00 pm. on Decanber 25", b) ~ B shall begin at 2:00 pm. on Deccmbc:a 25'" and end at 2:00 pm. on Decanber 26.... c) Motha' shall have ~ A in evm numbered )arS and ~1W'IfI B in odd numbered years. d) Father shall have Sq.rfft B in ellCll numbered )QI'S and Sq.ftfI A in odd numbered yean. 6. Easter visitation shalJ be divided into two ~1....ti: a) .\OJ. fJft A shall begin at 6:00 p.m. dw: Satuniay bcbe Easter SurdIy and end at 2:00 p.m. on Easter Sunday. b) ~...., . shall be;in II ,too p,m. Easter SuDda) .... end .. 6:00 p.m. on dw: Monday ~int Easter Sunda)'- d Mochc:t dIaU ,-"'le s.<I~"" . in C'\~ IIUmt.c:ud )an .. ~--4 .~ in odIJ 1IUI1Iha\\ld )WR. Ii) FIIher shall hiM .f..I.a:.... .-4 III not ! jj .","\lIol ~ .... $..-"" . .. t1dd DlIIJLlt .llflll ,.... \, ~ 7. Holiday periods of custody shall take precedence over all other scheduled periods of custody. 8. Im:spective to the foregoing, Father's Day shall be with Father, and Mother's Day shall be with Mother, and this visitation shall commence at 10:00 am. and end at 7:00 p.m. that same day. 9. Both parents shall take all reasonable measures to ensure the child is able to participate in any extracurricular activities she has signed up for. 10. Both parents shall permit reasonable telephone access to the child while the child is in his or her custody. I I . The parents are encouraged to acamunodate the reasonable requests of the other parent for a1tc:mations of lilY agreed upon schedule, as the circumstances and best interests of the child ~ 12. Each party sball be ...spu..sible to provide ttampol1ation in order to pielt the child up at the OOffiIbcdccnlel\t of their periods of visitation. 13. If either party hcmo brad1cs lilY of the provisions of this ~"""m, the other party WlI ha\-e the riJbt to brina IIIl)' IlC.'tiClI\s or IlC.'tiClI\s in law or equity for such brrach, and the ht~ party sbaII be IgpulllIibIe for the pI)1IICIU of an costs and rauonabIc IepI fees irnm:d by the other party in enbdna bc:rriabts under this A&lte..ld. 14. Neither perty sbIlI do lIII)1hina wbich may CSlJM. the Child from the olher. or injure the opinlon of the OIild as III the olher \lIl1)'. or wi\ich may hmlp<< the he IIld nabnI dmI-'ll'u, ". of the CIlW'IIove or ~ for the olher.-rtY. 15. The forgoing agreement and stipulation shall be effective immediately, and at the end of the school year either party may petition the court for modification. 16. In the event that no one files for modification prior to August 15, 2003, the order shall continue until further order of court. 17. The parties desire that this Stipulation and Agreement be made an Order of Court to the Court of Common Pleas of Cumberland County, which does, in fact, have jurisdiction over the issue of custody of the parties' minor Child and shall retain such jurisdiction should circumstances change and either party desire or require modification of said Order. 18. The parties agree that in making this Agreement, there has been no fraud, concealment, ovem:aching. coercion, or other unfair dealing on the part of the other. 19. The parties acknowledge that they have read and understand the provisions of this Apeement. Each party adnowtedges that the AlI'""......t is fair and equitable and that it is not the result of any duress or undue influence. BY THE COURT, r-.rt'.,,P '; 'v1)~ o \,0 .~# ~. >0- af ~ % ..;l ,. if, Sr: 8~ ):~-~. :r. ~r -.: g~ ""') 'jo N ~~ zr:~ t." ~~!i! " :: .- ct It. ~ d L) .. ,..,.. IJ~ I'~ :'::o~ MERLE E. HATTHElfS, JR., Plaintiff , , , IN THE COURT OF COHHON PLEAS OF CUMBERLAND COUNTY, PEN.VSYLVANIA v. . . CIVIL ACTION - LAtI NO. 96 - 5254 CIVIL TERM CIVIL /.CTION - CUSTODY LISA M. CRAMER, DeLendant , , , , COURT ORDER AND NOil, this 'S,il day of =1J... tnNJ-.I..~..I consideration of the attached Custod) Conciliation ordered and directed as follOll/'s: , 1996, upon Report, it i. 1. The Father, Merle E. Hatthew., Jr., and the Mother, Lis. H. Cr_er, ,h.ll enjoy shared legal custody of S_.nth. N. Matthews, born October 2, 1994- 2. The Hother, Lis. H. CrlUNr, .h.ll enjoy prim.ry physical custody of the minor child. J. The Father, Merle E. Matthews, Jr., ,hall enjoy period. of physical custody with the minor child a. follow.: A. On alternating weekend. cOGIlHncing Wedne.d.y .t S,OO p... unti.l Sunday at S:OO p... B. At .uch other tille. a. .gre.d upon by the p.artJ... 4. 'l'h. Christaaa holiday. .b..u .lv.y. be sh.red bftw.n the p.rUe. .,ith tM p.rtJ.. n.ching .n .gr....nt behl.." the..elve. with r..pect to alloc.tion of ti.. ",ith the .i.nor child. 5. Other -)01' holiday. dall be aU.rnded or dllu...d IS atre." upon by the parti... 6. The Hother .halJ 'Iv,y. Aave custody of lh_ _Jllor child on HoUI.r', o.r ."d tile ,.Uher "I"H ah...)'s hoiln cu.tody on '''thet', 0.,. TAe t1.. Ir... ,h.Jl be Ire. 'tOO .... untJl 5:00 p... fbi. provlaiOll .haU .up."..eeI. .n)' oth.". pI'OvJatoa 01 tIli. order, A 7. This order is entered pursuant to an agreement reached by the parties at a custody conciliation conference. In the event either party desires to modify this order at any time, that party may petition the Court to have the case against referred to the Custody Conciliator. By the court, '~/9' Lr..~ &-, Jv J. cc: James Xayer, Esquire Stephen Met. Dickinson School of Law Fa:a1ly Law Clinic TRUE COPY FI\OM RECORD 1ft rUlimony wIltrtof. I !lirt a;n1O Sotl my hIM IIld lilt MIl of said CCM1 II Caftlslt, h. !No l~r)"'i' ~ ".tJ. .... From March 1995 to June 1995 with an unknown male acquaintance at 430 S. Hanover Street, Apt, I, Carlisle, PA, From October 1994 to March 1995 with Maternal gmndmother and ~1ep grandfather, i"duline p, & William p, in Shermansdale. PA 4. The mother of the child is Lisa M, Cramer. currently residing at 8 Marilyn Drive, Carlisle, Pennsylvania 17013, She is single, 5. TIle father of the child is Merle E. Matthews, Jr" currently residing at RD #1, Elliotsburg, Pennsylvania 17024, He is single, 6, The relationship of Plaintiff to the child is that of father, The Plaintiff currently resides with the following pen;on(s): Name Relationship Merle E, Matthews. Sr. Paternal Grandfather Viola M, Matthews PatemaJ Grandmother 7. The relationship of the defendant to the child is that of mother, The Defendant currently resides with child and the followinl person(s): Name Relationship Todd · Boyfriend 8, Plaintiff has not panicipaled 8.~ a pany or wit-, or in anothef capacity. in othe-r Iitipllon ~'ol"'''tming the- CU!itody of the- child in thbt or anotheT rourt. Plaintiff has no information of a CIl'4l1tJy pn~nl COOI:ftl\inJ the clUld pendin, in a COlII1 of thill Cummonw~ Plaintiff does not know of .. peN1I\ not . puty to the pl'OI:ftdillp who has p1tyskal ClllItotly of the child Of claism to hI~ cll!itody or ,i'lttlllion riJlws with ~"t It} the chiU VERIFlCA nON OF PLEADINGS The foregoing document is based upon infonnation which has been gathered by my counsel and myself in the preparation of this action. The language of the document may, in part, be the language of my counsel and not my o\\n. I have read the statements made in this document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the contents of the statements are that of counsel, I have relied upon counsel in making this Verification. I undemand that false statements herein are made subject to the penalties of 18 PA. C.S. S4904, relating to unsworn falsification to authorities. Date: 4, /9, 'J?'1 /, r . 7h :td.. . /J '1"/... { 1"'1 ct--:'" .-..Jl.... . J996 , MERLE E. MATrHEWS, JR., PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY NO,96-5254 CIVIL v. LISA M. CRAMER, DEFENDANT PRAECIPE TO ENTER APPEARANCE To the Prothonotary: Please enter the appearance of the Family Law Clinic on behalf of Lisa M. Cnmer. the defendant. in the above captioned matter, )J w w.-IJ U<- 4-1 19!1Jz ~A- iLl:h Stepben A, Mctz Certified 1.qaIlntem ,'-1< ( 71' ccA L.. L'- BERT E. R.-\INS OMAS M. 1LACE KATK8UNEC.~ON Supervising Anorney GAIL R, SHEARER Staff Attorney FAMILY LAW CUNlC 45 North Pitt Smet Carlisle. PA 17013 7171243-2968 , ~ \Il it: -,. ~~ 8 J - :"'~ t5 .~,- '-J~ .' :.:.i '& ;t; '-\:.J c; ....)- _-r >~~ ~t I :;f~ -. -- : ",il"1l: i- e,' ,..~~,4. ;., l!.. \J') a Ci t.".. (1J .. ...- . . ",::["-,, j;:;:~' )17 MERLE E. MATTHEtiS, JR., Plaintiff . . IN THE COURT OF COHHON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAti NO. 96 - 5254 CIVIL TERM CIVIL ACTION - CUSTODY . . : v. : : LISA M. CRAMER, Defend.nt . . : : COURT ORDER AND NOfi, thi" ~ d.y of -lJ..tJ,....l,.u con"ideration of the .ttached Cu"tody Conciliation ordered and directed e" follow,,: , 1996, upon Report, it is 1. The Father, Herle E. Hatthews, Jr., end the Mother, Li"a H. CrlUNr, shall enjoy sbared leg.l custody of Sama.ntha N. Mattbews, born October 2, 1994. 2. The Hother, Li.. H. CrlUNr, sball enjoy prilllary physical custody of the .inor cbild. J. Th. 'ather, Herle E. Hat thews, Jr., .h.ll enjoy period" of physic.l cu.tody witb the .inor child e. follows, A. On .lternating weekend. c~ncing Jiedne.day at 5:00 p... until Sund.y .t 5:00 p... B. At such other t.t.ea .s .greed upon by the partie.. 4. fhe ChristINa hoHday. .hall elw.ys be sh.red bet.....n the partiea wlth the p41rtie. re.ching .n .gr....nt between th....lv.. with re.pect to .lloc.tion of tt.e witb the .inor cbild. 5. Other ..jor holidey. .h.ll be .lternated or .bued .. IIgreed upon by the parti.s. I. fhe Hother .b.ll elw.y. ha..e cu.tody of the .iner child on Ifotller'. o.y IInd tile 'atber sMill .lwaya ha..e ev.tody on 'ather'. o.y. fbe tt.e fr_ ahell be trea "00 .... until 5:00 p... fhi. proyj.Jon .ball aup.nede IIny other proviaJon of tbi. order. r-tro ,m:CE f',: " .. ....-.,,..,""\-.~ ,.J.,;il l,,,, .~~" If" ,.. "'Q . ,) , S;1 .1: .1. ~ C" . '. \".';\",1.., . ~..;, I 1 FcN~.s)"'V.~NA .. . .. .' , .- 7. 'this order is entered pursuant to an agreement reached by the parties at a custody conciliation conference. In the event either party desires to modify this order at any time, that party may petition the Court to have the case against referred to the Custody Conciliator. By the court, . , cc: JlUNs lCayer, Bsquire Stephen Hetz Dickinson School of La"" F4IItlly Law Clinic ~....I'Y'~.I'.J... II}U/'c. ' A'f. , . .' ~ MERLE E. MATTHEWS, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . : v. : CIVIL ACTION - LAW . . LISA M. CRAMER, . NO. 96 - 5254 CIVIL TBRJf . Defendant : . CIVIL ACTION - CUSTODY . CONCILIATION CONFERENCE SUHHARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY CIVIL RULE OF PROCBDURE 1915.3-B(bJ, the undersigned Custody Conciliator submits the following report: 1. rhe information pertaining to the child who is subject of this litigation is as follows: S_antha N. Matthews, born October 2, 1994 2. A Conciliation Conference was held on Novelllber 7, 1996. Present were the Father, Herle B. Hatthews, Jr., with hi. attorney, James Xayer, Bsquire, and the Hother, Li.a H. CrlUNr, with her attorney, Stephen Hetz ot the Dickinson School at Law F4IItily Law Clinic. J. The partie. agreed to the entry ot an order in the fora B. attached. 111/'{(3.u Date f