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Home My WebLink About97-03008 ~ ~ ~ u ~ ~ ~ o ....q 8 ~ - , .. .::It .. ~ - ~ >: ,;,.j: .(,::.~r: " :~\--j~~~:~;:::' /' . ,.~-",. ,.--,.,,;, .:::,; ::-~~~~~\~::~ ;', . :'" ;~-.-:"' :~.~-; ~:'1;,.;,"" '1"'-'- ...... --.('. . ".- ,," ,{ .,~. '.~"':':-': ' - ( I , .~ ,.'-, " ,-: .";' . , . -', ~,'- .. '. i ! ;-, 7.: ,.. II' ( ): i ~ c" /i: ~.l ;' Li.' . i " L ~ '~. ~ 'l ~,.... ci ", '"', "\ ..]' ~ ~~ ~ l', <:.}.. . , ,~ ('; .( '\ (~ \'0 I \~ ~ r:'tL ~ .J '" .~~' ^'1 1)., ! \\. ......~ \'-::s " 0. .' ~ "j ~") ;~ ~ ~ r- , ., ";' I,} ~ F "'< 0'" ~~ N & t/) ~ a.rn i iil ~~ ~ 5~~E ! ..:l , > w... J:! H 9 iii olI~~~I~~ > 0: U".. H 2 , ~ "" u 9 ~lu~ ~f;:' [:)ii5 ~~ 8'a :>< I- z fE F::' - ~8 i u..a:::I:J _t:- o.. Z~lt~ t:-~ .u ~] 8! . l:: c( ~ a. .... .. .... :E: it I fSo: . ..38 fillil I"- > - 01 6:1 - ~~ . ~ ~ ~ g . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KENNETH P. THEOBOLD, Plaintiff V. I I I I I I I CIVIL ACTION - LAW IN CUSTODY NO. 97- ,3cc.1? CIVIL TERM JODY L. THEOBOLD, Defendant ORDER OF COURT AND NOW, the parties, by and through their attorneys, stipulate and agree as followsl 1, KBnneth P. Theobald, herBinafter referrBd to as "Father' and Jody L. Theobald, hereinaftBr referred to as "Mother" are the natural parBnts of the two (2) minor children, Nathan E. ThBObold, date of birth JunB 17, 1984 and Brent M. ThBObold, date of birth November 1, 1988, hereinafter rBferred to as ~inor childrBn" . 2. FathBr and Mother shall share legal custody of the minor children. 3. FathBr shall have primary physical custody of the minor children, subjBct to MothBr's partial physical custody as follows I a. One evening each week from after school (3100 p.m. in the summBrtime) until 8100 p,m. as mutually arranged in advance of the datB; If the partiBs cannot agreB on a specific evening, thBn said physical custody shall occur on Tuesday eVBnings WBBkly. e..-~.-roo~~Ma b. AltBrnating weBkends from Friday after school (3100 p.m. in the summBrtimB) until Sunday at 6100 p.m. c. Two (2) nonconsecutive WBBks during thB summBr with thirty (30) days writtBn notice to thB FathBr with the understanding that FathBr shall also bB entitled to two (2) nonconsBcutive wBeks during the summer with thirty (30) days writtBn notice to Mother. d. AltBrnating holidays, which holidays include New Years Day, EastBr, MBmorial Day, July 4th, and Labor Day~ The rotation will start with Mother having MBmorial Day in 1997 and Father having July 4th and alternating thereafter commencing at 6100 p,m. the day prBceding said holiday and Bnding at 6100 p.m, on the holiday. e. Alternating Thanksgiving Day and the Friday therBafter so that Mother will hav.e Thanksgiving Day from 10100 a.m. until 6100 p,m. in 1997 and odd YBars thereaftBr and FathBr will have the Friday after Thanksgiving in 1997 and odd YBars thBreaftBr from 10100 a,m. until 6100 p.m.~ FathBr shall haVB Thanksgiving Day from 10100 a.m. until 6100 p,m. in 1998 and even years thereafter and Mother shall have the Friday following Thanksgiving Day from 10100 until 6100 p.m. in 1998 and even years thBreafter. f. AltBrnating the Christmas holiday in two blocks so that in 1997 and odd years thereafter, Mother shall e:- _........ ..~Am haVB DBcember 23 at noon until DecBmbBr 25 at noon and Father shall have DBcBmbBr 25 at noon until DBcember 27 at noon~ And in 1998 and even YBars thereafter, Father shall have DBcBmbBr 23 at noon until December 25 at noon and MothBr shall havB DBcembBr 25 at noon until December 27 at noon. g. Each MothBr's Day from 10100 a.m. until 6100 p.m. with the undBrstanding that thB childrBn will bB with FathBr on Father's Day from 10100 a.m. until 6100 p.m. h. Such othBr times as thB partiBs may mutually agrBB, and arrange by notice rBasonably in advance of thB occasion. 4. Mother agrees that it is in thB minor childrBns' best interBst that she not consume alcoholic beverages during pBriods that the children are in her physical custody. It is BxprBssly prohibited that BithBr party consumB alcoholic bBvBrages and operatB a motor vehicle when the children are in thBir carB and custody. Mother agrees that she shall not havB consumBd any alcoholic bBvBrages within twelve (12) hours prior to any pBriod of her taking physical custody of minor children. 5. This Stipulation shall be BntBred as an OrdBr of the Court. ~1",,",,_.....n~A&Jl. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KENNETH P. THEOBOLD, Plaintiff , , V, I I I I I I CIVIL ACTION - LAW IN CUSTODY NO. 97- 3/rOf CIVIL TERM JODY L. THEOBOLD, Defendant AND NOW, CUSTODY AGREEMENT this ~day of -J W1G- , 1997, bBtwBen KBnneth P. ThBObold, Plaintiff, and Jody L. Theobold, DBfendant, the partiBs hBrBby enter into this agreemBnt rBlativB to thB custody of their minor children, Nathan E. Theobold, born JunB 17, 1984 and BrBnt M. ThBObold, born NovembBr 1, 1988, 1. KennBth P. ThBObold, hBrBinafter rBferred to as "FathBr" and Jody L. ThBObo1d, hBrBinafter rBferred to as "Mother" arB thB natural parents of the two (2) minor children, Nathan E. Theobold, datB of birth June 17, 1984 and BrBnt M. Theobold, date of birth NovembBr 1, 1988, hBreinaftBr rBferred to as "minor children" . 2. Father and Mother shall share legal custody of the minor childrBn. 3. Father shall have primary physical custody of thB minor children, SUbjBCt to MothBr's partial physical custody as follows I a. OnB evening Bach week from after school (3100 p.m. in the summertimB) until 8100 p,m. as mutually arranged ~DK\IInlO'.Na in advance of the datB; If thB partiBs cannot agrBB on a specific eVBning, then said physical custody shall occur on TUBsday eVBnings weekly, b. Alternating wBBkBnds from Friday after school (3:00 p.m. in the summert1mB) until Sunday at 6:00 p,m. c. Two (2) nonconsecutive weeks during the summBr with thirty (30) days writtBn notice to the FathBr with the undBrstanding that FathBr shall also bB Bntitled to two (2) nonconsecutivB weBks during the summer with thirty (30) days written notice to MothBr. d. AltBrnating holidays, which holidays include NBW Years Day, EastBr, Memorial Day, July 4th, and Labor Day; The rotation will start with MothBr having MBmorial Day in 1997 and FathBr having July 4th and altBrnating thBreaftBr commBncing at 6:00 p.m, the day precBding said holiday and ending at 6:00 p.m. on the holiday. B. Alternating Thanksgiving Day and thB Friday thereafter so that Mother will have Thanksgiving Day from 10:00 a.m. until 6:00 p.m. in 1997 and odd years thBreaftBr and Father will havB thB Friday aftBr Thanksgiving in 1997 and odd years thereafter from 10:00 a.m. until 6:00 p.m.; Father shall have Thanksgiving Day from 10:00 a.m. until 6:00 p.m. in 1998 and even years thBrBaftBr and MothBr shall have the Friday following Thanksgiving Day from 10:00 until ~DN'C.'Wt'lXJTAm. 6:00 p.m. in 1998 and eVBn years thereaftBr. f. Alternating the Christmas holiday in two blocks so that in 1997 and odd years thBrBafter, MothBr shall havB DecembBr 23 at noon until DecBmber 25 at noon and Father shall have DBcBmber 25 at noon until DBcBmber 27 at noonl And in 1998 and eVBn years thBreafter, Father shall havB DBcembBr 23 at noon until DecBmbBr 25 at noon and MothBr shall have DBcBmbBr 25 at noon until DecembBr 27 at noon. g. Each Mother's Day from 10:00 a.m. until 6:00 p.m. with thB understanding that the children will bB with FathBr on FathBr's Day from 10:00 a.m. until 6:00 p.m, h. Such othBr timBS as thB parties may mutually agree, and arrange by noticB rBasonably in advance of the occasion. 4. Mother agrBes that it is in the minor childrBns' bBSt interest that ShB not consume alcoholic beveragBs during periods that thB childrBn are in hBr physical custody. It is expressly prohibitBd that BithBr party consumB alcoholic beveragBs and operate a motor vBhicle whBn the children arB in their care and custody, Mother agrees that she shall not have consumed any alcoholic bBveragBs within tWBlvB (12) hours prior to any period of her taking physical custody of minor children. ~_'''''"'' _.....~ft~Ma iT- In ~ ;.r ~ ~Jr~ 9 :.;) Q~~ !}(, :J: u;e 'J~.:t ..... C"fi";"""", r)~ L~[!~ ". - .'ti'ln It.It... .,' ...IZ j....Li I -. m~ ...... ., s ,,- t... -, 'I. 0 ~. 0 :;5 ~ <:) u :E II:: ril Eo< o-:l >< H Eo< > Z H ::I U o u< to HO t:lZ 0 z< ..... <> I o-:lo-:l I II:: >< r- ril CIl 0\ lllZ :E Z ' ::Iril 0 UA. Z :J: < o-:ll Z o H>< Eo<t:l uo <Eo< CIl o-:l::l HU > HZ UH . " 11-I 11-I ., r:: '>1 III .-i A. .jJ r:: III 'tl r:: QJ 11-I QJ t:l >< r.. H >< t:l t:l 00 :E Eo< CIl 0::1 Eo< U Z r.. o 0 H " Eo< II:: H ril Eo< t:l ril II:: A. 0 . t:l o-:l o III o ril :>:: Eo< ~ II:: , rz:I > > o o :>:: , A. :>:: Eo< ril Z Z ril :.: . o-:l >< t:l o ,., III II: - " ::J _ g ~ ~ ~ III l1-l n ~ ~Z ~~r;~ l.l -: III Ii; ~ ;. s: 1'"\ _ ~ oJ ,., ....1 z := 2 ;.- 0<<1 -:!-o:= ~ 1'"\ ~ ~ " II II: .... ~ ~ " < III 7. ~ p.. ,.J:;: CI) ~ w iii ::J ;:~Oz; :z:: -: C ::J _ 0 0: ..J a <: o.l \) - ~ . ~ . JUN ~ 5 20~ 'J " ~', . ': ,-I""'.: "'e, . '.~'" ~ .~! . ~IHll~ 1.~!I~~tj~ll~", qJ I ~! Sl~ t \ ,'\'l:1,{f'... .....,. '~11 "wAf\~ _ ~t~. ~v '1,;.r"J"1.i'. in' 't: , 19111't'(~ 1 'If. N:--IO.... j ", :', i~" .~,.I".,ti ;:.'1 ,. ,'''~. '.~r, '...... . ". ......./.i...~l ;UI11!W;\~J' \ ,por....1 ] ,.,~.. ... . ,.h' '-:;'~,:i.'q,),~ '::,0. .~ -'0,.:\1, '1,.\.7.17.)24 . B~,{i:, "', '....,';oi I. ,I, :'.',. t. '''_...._,..__~ " .. '''I, \ . ~'l . ~ :a:i.~':'~l;"f'..ll';-'.,...:.c I/~" :';"l.~.! .., '. '}... ~\, '1t:~};.'2" ~ \ ':~' "l1.~, "'J )~ (1 ': ~", ,. .' ~ ~ ',Y ,*..r....:.~i..~..<t,t~.t~~t\~i...ll~~ ~\t"""~~",,If~\'7J!.'LtQti~~~5.7;1;~!'~:'f;.~:/'''~l.L~'':~'~!: 'A,1TOflrIUI, ....!". ., .. L....J......~_--'---'j. _l..........L.o. _.1.... ...,t....... I ... . _."..,..... .'. , l "'. . w .~ . --... ~ IN THE COURT OF COMMON PLEAS QE' CUMBERLAND COUNTY, PENNSYLVANIA I\gNNI;"H P. 'l'HEOBOLD, Plaintiff V, JODY L. THEOBOLD, Defendant CIVIL ACTION - LAW IN CUSTODY NO. 97- ~~C,(;f.; CIVIL ~l'ER!.: ORDER OF COURT AND NOW, the parti~5, by and through their attorn~ys, stipulate and agree as follows: 1. Kenneth P. Theobold, hereinafter referred to as "Father' and Jody L. Theobold, hereinafter referred to liB 'l~:),=hEll:' are the natural parents of the two (2) minor children, Na~t.an E. Theobold, date of birth June 17,1994 and Brent M. Theelbotc, date of birth November 1, 1998, hereinafter referred to as "rlir,Q: children" . 2. Father and Mother shall share legal custody elf ~f ,= minor children. 3. Father shall have primary physical custody of t.1C :ninoI.' children, subject to Mother's partial physical custody ,!:3 follows: a. One evening each week from after school 1.3:l.C p.m. in the swnmertime) until 9:00 p.m. as mutually ~l.rangecl in advance of the date; If the parties cannot, :l~l',"! on a specific evening, then said physical 1:\IStoq' .1 a 11 occur on Tuesday evenings weekly. EXHIB1T "A" c ~lIJiCll"',:~"IlntlO'f\1lG.l*lI.D t.>>k'\lstullY,o.l.2 ---.---...--.-- b. Alternating wBekends from Friday after nchoCll (3:00 p.m. in thB summertime) until Sunday lit 6:(10 p.m. c. Two (2) nonconsecutive weBks during tho sUJrJf,er with thirty (30) days writtBn notice to thB Father with thB understanding that Father shall also be en~itled to two (2) nonconsecutive weeks during the sumn.er with thirty (30) days writtBn notice to Mother. d. Alternating holidays, which holidays include New Years Day, Easter, Memorial Day, July 4th, and L,lbor Day; The rotation will start with Mother having Memorial Day in 1997 and Father having July 4th ilnd alternating thereafter commencing at 6:00 p,m. the day preceding said holiday and ending at 6:00 p.m. on the holiday. e. Alternating Thanksgiving Day and the Friday thereafter so that Mother will hav:e Thanksgiving [tal' from 10:00 a.m. until 6:00 p.m. in 1997 and odd yeaJ.'s thereafter and FathBr will havB the Friday al:ter Thanksgiving in 1997 and odd years thereafter from 10100 a.m. until 6100 p.m.; Father shall have Thanksgiving Day from 10:00 a.m. until 6100 p.rn, In 1998 and even years therBafter and Mother shall have the Friday following Thanksgiving Day from 10:011 until 6100 p.m. in 1998 and Bven years therBafte:. f. Al ternating the Christmas holiday in two blo'~ks so that in 1997 and odd years thereafter, Mother shaH e.~T.Q ..--'---.'.'-----1 havB December 23 at noon until DecBmber 25 i11: nClCln and Father shall have DBcBmbBr 25 at noon until l>ece'OIbor 27 at noon; And in 1998 and eVBn years thereafter, F'ather shall have DBcembBr 23 at noon until DBcembEIt' 25 at noon and Mother shall have December 25 at ncon un~ll December 27 at noon. g. Each Mother's Day from 10:00 a.m. until 6:00 p.m, with the understanding that thB children will 1:e ldth FathBr on Father's Day from 10:00 a.m. until 6:00 p.m. h. Such other times as the parties may mutually agreB, and arrangB by notice reasonably in advancE. of the occasion. 4. Mother agrees that it is in the minor childrens' bo~st interBst that ShB not consume alcoholic beverages duri~g periods that the children are in her physical custody. It is expressly prohibited that either party consume alcoholic be'/erages and opBrate a motor vehicle when thB children are in theIr care and custody. Mother agrBes that she shall not have consumed any alcoholic beverages within tWBlve (12) hours prior to any p(~::iod of her taking physical custody of minor children. 5. This Stipulation shall bB entered as an Oreer of 1:l1e Court. (.~~,..ua ~~ _'" ........... 'Aia. -,........... .......-I..l.....~i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KENNETH P. THEOBOLD, Plaintiff V. CIVIL ACTION - LAW IN CUSTODY JODY L. THEOBOLD, Defendant NO. 97- CIVIL TEIU~ CUSTODY AGREEMENT AND NOW, this ____ day of , 1997, beth'een Kenneth P. Theobold, Plaintiff, and Jody L. Theobold, [Jef03ndant, thB parties hereby Bnter into this agreemBnt relativB t.o the custody of their minor children, Nathan E. Theobold, be,rn June 17, 1984 and BrBnt M. Theobold, born NovembBr 1, 1988. 1. Kenneth P. Theobald, hereinafter referred to as "Father" and Jody L. Theobald, hereinafter referred to as "M<nher' are thB natural parents of the two (2) minor children, Nal:h~n E. Theobold, date of birth June 17, 1984 and Brent M. Theobald, da'te of birth NovBmbBr 1, 1988, hereinafter referred to as ~ninor children' . 2. FathBr and MothBr shall share IBgal custody of tht~ minor childrBn. 3. Father shall have primary physical custody of the minor childrBn, subject to Mother's partial physical custody as follows: a. One evening each week from after school ~3:0u p.m. in the summertime) until 8:00 p.m. as mutually arn,nged c.~~J>>flL'WrOO'ACII. ............... ................. in advancB of the datB7 If the parties cannot <',9rne on a specific BVBning, then said physical custody ehllll occur on Tuesday eVBnings weekly. b. AltBrnating weBkBnds from Friday afteI' sl:hlml (3:00 p.m. in thB summertime) until Sunday at 6:00 p.m. c. Two (2) nonconsecutive weeks during the swruner with thirty (30) days written notice to the Fath(~r with the understanding that FathBr shall also bB enti.1:111d to two (2) nonconsecutive weBks during the swnner \dth thirty (30) days written notice to Mother. d, AltBrnating hOlidays, which holidays include New Years Day, Easter, Memorial Day, July 4th, and Laber Day; The rotation will start with Mother having Memorial Day in 1997 and FathBr having July ,Ith and alternating thereafter commencing at 6:00 p.m. t:le day preceding said holiday and ending at 6:00 p.:1I. OIl the holiday. e. AltBrnating Thanksgiving Day and the Fr.lday thBreafter so that Mother will have Thanksgi"ing [lay from 10:00 a.m. until 6:00 p.m. in 1997 and cldd years thBreaftBr and Father will have the Friday afte:t' Thanksgiving in 1997 and odd years thereafteI' f::cm 10:00 a.m. until 6:00 p.m.; Father shall have Thanksgiving Day from 10:00 a.m. until 6:00 p,m. in 1998 and even years thereafter and Mother uhall h'~'le the Friday fOllowing Thanksgiving Day fl'om 10: OC tu:t.i.l C'~~I:DftaIrnlcly.AlJl. ..... ....,. ._..1'"'' ".....'..1 6100 p.m. in 1998 and even years ther'3aftBJ:. f. AltBrnating the Christmas holiday ill two b!.ocks so that in 1997 and odd years thereafter, Mt)ther s:l!lll have December 23 at noon until DBcBmber 25 nt n()l)n llnd Father shall have December 25 at noon until DEcmnb'~r 27 at noon; And in 1998 and even years thereaf'~or, l'a':her shall havB December 23 at noon until Decemb.lr 2:, al: noon and Mother shall have DecembBr 25 at nClon until December 27 at noon. g. Each MothBr's Day from 10100 a.m. until 6:00 p.m. with the understanding that the children will be with Father on Father's Day from 10:00 a.m. until 6:00 p.m. h. Such other times as the parties may mutuaJ.ly agree, and arrange by notice reasonably in adveLll'='" of the occasion. 4. Mother agrees that it is in thB minor childrena' bes': interest that she not consume alcoholic beverages durL'Iq ptlriods that thB children arB in her physical custody. It is 13xpro!lsly prohibitBd that eithBr party conSWDB alcoholic beveragl~a and operate a motor vehicle when the children are in their care and custody, Mother agrees that she shall not have consWDE!d !lTe}' alcoholic bevBrages within twelve (12) hours prior to eLllY r-eri.od of hBr taking physical custody of minor children. C'~""I""~,.A(A " b, Alternating weekends from Friday after school (3:00 p,m, in the summertime) until Sunday at 6:00 p,m. c, Two (2) nonconsecutive weeks during the summer with thirty (30) days written notice to the Father with the understanding that Father shall also be entitled to two (2) nonconsecutive weeks during the summer with thirty (30) days written notice to Mother, d. Alternating holidays, which holidays include New Years Day, Easter, Memorial Day, July 4th and Labor Day. The rotation will start with Mother having Easter in 2000 and Father having Memorial Day and alternating thereafter commencing at 6:00 p.m. the day preceding said holiday and ending at 6:00 p,m, on the holiday. e. Alternating Thanksgiving Day and the Friday thereafter so that Mother will have Thanksgiving Day from 10:00 a,m, until 6:00 p,m. in 2000 and even years thereafter, and Father will have the Friday after Thanksgiving in 2000 and even years thereafter from 10:00 A.M. until 6:00 p,m. Father shall have Thanksgiving Day from 10:00 a.m. until 6:00 p,m, in 200 I and odd years thereafter, and Mother shall have the Friday following Thanksgiving Day from 10:00 until 6:00 p.m, in 200 I and odd years thereafter. f. Alternating the Christmas holiday in two blocks so that in 2000 and even years thereafter, Mother shall have December 23 at noon until December 25 at noon, and Father shall have December 25 at noon until December 27 at noon, In 2001 and odd years thereafter, Father