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XN THI COURT CONNON PLIAS or CUNI.RLAND COUNTY P.""SYLVANXA
Gayle I!J, Mowllrlll, Civil Action . LaW
Plaintiff
Vs, 1996 - 'J'..J'I I' f..'....:J "/t-.4....'"
Casey W, MOWIII:S,
Defendant Custody
STXPULATION ANP AQRIIMINT 0' Tal PARTXIS
NOW'comlls the Plaintiff, Gayle 8. Mowel:S, by hllr
attorney, Barbara a. Townsend, and the Oefendant, Casey W.
Mowel:S, pl:O se, and stipulate and agree as followsl
1 .
Plaintiff Gayle B. Mowel:s is sn adult individual
reBlding at Borough of Shippensburg, cumberland County,
Pennsylvania, with a mailing address of 114 East King Street,
Shippensburg, PA 17257.
2.
ceser W. Mowers, Defendant herein, is en adult
individua residing at 4625 Blinn Hill Road, Dresden, Lincoln
county, ME 04324.
3,
Plaintiff and Def~ndant are the natural parents of
Garrett D. Mowers, born February 20, 1994, and Alexis M.
Mowers, born August 4, 1995. The children were born in
wedlock.
4.
For the paet five years the children has resided at the
following addresses and with the following persons I
From birth until May 1994 Garrett D. Mowers resided at 291
800z Road, Shippensburg, Pennsylvania, with Plaintiff, Gayle
E. Mowers.
From June 1994 until September 1995 Gal:rett D. Mowers resided
at Lexington Park, Maryland with Plaintiff, Gayle E. Mowers
and Defendant, Casey W, Mowers.
FJ:'om OotobllJ:' 1995 until Janullry 15, 1996 ClaJ:'J:'lItt P. MOWllJ:'lI
and AlllKis M, MowllJ:'s J:'esided at 4625 alinn Hill Road,
PJ:'lISdlln, ~incoln County, Maine with Plaintiff, Gayle m,
Mowers and Defendant, casey W, Mowers,
From Janu8J:'Y 16, 199d until present Garrett D. Mowers and
Alexis M. MoweJ:'s resided at 114 Ea~~ King StJ:'eet,
shipplInsburg, Cumberland County, PlInnsylvania with Plaint if f,
Gayle E. MoweJ:'s.
5.
The parties agree that the court may
ordllJ:' with rllgaJ:'d to the custody of their
GaJ:'J:'ett and Alexisl
enteJ:' the following
minoJ:' childJ:'en,
ORDER OF COURT
. 1996. the within stipulation
and agreement having~en presented, considered and
ordeJ:'lId filed, IT IS HEREBY ORDERED that Gayle E.
Mowers, heJ:'einafter Mother, and Casey W. MoweJ:'s,
heJ:'einafter Father, shall have joint legal custody of
their children, Garrett D. Mowers, bOJ:'n February 20,
1994, age 2. and Alexis M. Mowers, born August 4, 1995,
age 1. Mother shall have primary residential custody of
the paJ:'ties' minor children. SUbject, nevertheless, to
Father's right of partial custody as followsl
A. Father may p.xercise his right to partial custody one
week a month when his work schedule permits and informs
Mother the firot of each month as to when he would like
to exercise his week of partial custody.
a. On major holidays, which holidays shall be shared
equally, on an alternating annual basis beginning with
the following schedulel on Thanksgiving 1996, from 9100
a.m. until 9100 p.m. with Mother, and fr~m 9100 a.m.
until 9100 p.m. with Father on New Years Day 1997, said
alteJ:'nating holidays to include Presidents Day. Easter.
Memorial Day, July 4th, Labor Day. Thanksgiving. and New
Years Day. In the event that a holiday is followed by a
school day, and Father is exercising partial custody,
the holiday will end at 8100 p.m.
c. For Christmas in odd years Father ahall have the
children from 1100 p,m, on December 25 until BIOO p.m,
December 26, Mother shall have the children from BIOO
a,m, Oecember 24 to 1100 p,lII. December 2150 'l'hlt balance
of the school vAcation shall be divided equally. In
even years the schedule will be reversed.
0, Mother shall have the children Mother's Day from
~IOO a.m. until 8100 p.m. Father shall have th$
children ~very Father's Day from 9100 a.m. until BIOO
p,m.
reo Holiday cUlltody shall have precedence over regular
custody.
F. When the children start school, Father shall have
the children for two full weeks of esch of the three
summer months and any additional times as the parties
may agree. Pather must give not ice to mother by May 1
of each year of what two weeks he wishes to have
children in June, and the same for each month following,
during tne summer vacation.
o. Transportation shall be shared equally between the
parties.
H. Mother and Father shall notify the other parent at
any time that Garrett and/or Alexis is ill and is
treated by a physician. Voluntary procedures shall be
fully discussed prior to giving consent.
I. Neither parent shall allow anyone to make derQgatory
remarks regarding the other parent in the presence of
the children. Each parent shall have a positive duty to
uphold the other parent as someone worthy of the
children's respect and love.
J. Father's partial custody is based upon his
availability due to his work sr.hedule with the United
States Navy and will not be discriminated against if he
is unavailable for any periods of partial custody
because conflicting schedules. Mother shall be liberal
in permitting makeup time of partial custody if
requested because of Father's work schedule.
By the Court,
J.