HomeMy WebLinkAbout00-02599
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IN RE: CUSTODY OF
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
: CIVIL ACTION - LAW
NICOLE ANNE-MARIE PUGH
: NO. 00- ~59f CIVIL TERM
: CUSTODY
ORDER OF COURT
AND NOW, this I~ day of fII ~ ' 2000, the parties hereto
having stipulated and agreed with regard to custody of Nicole Anne-Marie Pugh, born
,
January 23, 1988, it is hereby ordered and decreed, as follows:
1.
Shared legal custody of said child as conternplated by 23 Pa.C.S. ~5302 will be in
both of the parties hereto.
2.
Shared physical custody of said child shall be in both parties with the schedule of
shared custody to be resolved by the parties upon a flexible basis in accordance with their
mutual agreernent.
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WAYNEF. SHADE Wayne F. Shade, Esquire
Attorney at Law
53 West Pomfret Street
Carlisle, Pennsylvania
17013
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WAYNEF.SHADE
Attorney at Law
53 West Pomfret Street
Carlisle, Pennsylvania
170B
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IN RE: CUSTODY OF
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
NICOLE ANNE-MARIE PUGH
: NO. 00-
CIVIL TERM
: CUSTODY
STIPULATION FOR CillLD CUSTODY
AND NOW, this 27th day of April, 2000, corne the parties hereto and with
regard to custody of Nicole Anne-Marie Pugh, born January 23, 1988, stipulate and agree,
as follows:
1.
KRISTIN A. PUGH of 55 Marilyn Drive, Carlisle, Cumberland County,
Pennsylvania, is the biological mother of Nicole Anne-Marie Pugh.
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2.
JOANNE M. ROSSI of 105 Beagle Club Road, Carlisle, Cumberland County,
Pennsylvania, is the maternal grandmother of Nicole Anne-Marie Pugh.
3.
The father of the child has never seen the child, and his whereabouts are unknown.
4.
There have never been judicial proceedings or a Court Order concerning custody
of the child in any jurisdiction.
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5.
The mother of the child will be moving to the State of Texas to obtain
ernployment.
6.
It is the desire and intention of both parties hereto and the child that the child
rernain in Cumberland County, Pennsylvania, in residence with her rnaternal grandmother
until the rnother of the child is situated in Texas.
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7.
The Pennsylvania Employes' Benefits Trust Fund, the health insurance carrier for
the rnatemal grandmother, requires an Order of Court in order to cover the child for
health insurance purposes.
8.
Without the benefit of the requested Order, the child would be without health
insurance because the rnother has no health insurance.
9.
It is the desire and intention of the parties hereto that custody of said child shall be
as set forth in the foregoing Order of Court so as to facilitate the necessary health
insurance coverage.
10.
Should either party at anytime in the future petition the Court for a modification of
WAYNEF. SHADE
Attomey at Law this Order, it shall not be necessary for the party to show a change in circumstances and
53 West Pomftet Street
Carlisle, Pennsylvania
17013
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WAYNEF. SHADE
Attorney at Law
53 West Pomfret Street
Carlisle, Pennsylvania
17013
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all relevant facts and circumstances shall be subject to judicial review and not only those
existing subsequently to the entry of this Order.
c.
11.
It is the desire and intention of the parties hereto that this Stipulation for Child
Custody be entered in the Court of Common Pleas ofCurnberland County, Pennsylvania,
and that it be endorsed as an Order of Court so as to have the full effect thereof.
Respectfully submitted,
v~~ rSl!m
Wayne F Shade, Esquire
Attorney for the parties
I verify that the staternents rnade'in the foregoing Stipulation are true and correct.
I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
~4904, relating to unsworn falsification to authorities.
Date: April 27, 2000
JLL AP0b
Kristin A. Pugh
I verify that the stateijlents made in the foregoing Stipulation are true and correct.
I understand that false statements herein are rnade subject to the penalties of 18 Pa. C.S.
~4904, relating to unsworn falsification to authorities.
Dme: April 27, 2000
~ om. t-.
Jo eM. ROSSI
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