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Home My WebLink About97-05293 " I't I It' 'I , , I' , '" , " 'I , , J , Ii ~ II " " , , ,<,J ",,'II r " , , /, " " I' " 'f' ~ " , " , ' , ' I, ,11 , ",. It-,' 1. <'i " ,I ,r-I ,I , , 'il , , ;1 1;1 .' 'I , , ~ ~ u 3 a ~ " , '~ , " , , " , i " 'I, , " " I"i ,I, ',' ... ,',', !' , , 'i , , "i " , , , , , 1" , , , II ,). , . ~ , . , ' 1;' J , II), , , , ", " , , , , , , , , , , , , " ' , ' " " i" , " , " "I , ' " I' Ij , , " ,! , " " ,,-' " ,I ;J , , " , , ',i . , , ,,' J" " , " , , " ,'i' " , , " , , " , " \' , , , , 'I ,II , ' ': ' '.- -' . ~. " r " ..:, l" , , '! . .., " " " 1 ~ l. I~) Ci '" l'\, I l , .14 . , , i " (.'::1 ',) I ,. , (.I' ~ ~ I ~ III J!; . .. ... 0 0 r ;:;: ~ ~ ... ... -- J . . IW.~"'''''''U''.''U''''."U' l'OfiIllIMlH ".~......nw.IIOlUlOW",",,""""" L..O""'II SUlATlLLl. SCHI"I\lAN, BROWN ac CALIIOON, p.c. Sum 291 20116 fJNIJI...mlWN li1An HAU.lftlll11l11,PA l11IA.9+f1J ($;~JAA ~ 9 1998 . , ." ~.. .. , , . ~; " ,I (~~J , , " .- " ". , 1 , , , , ol, I, \ ~ ! <1, , t , 1 '. ) I, I C;, " t..) r~ C' I,J . ' . .................".......... I'MJIItCH .:IIT J~............_..,.,.,..,......:T?Il . U 0: J ~ ~ j!~: HII ~ ~ i ~ ~I~~ J ~ ,," " " , , " " J,I .' . -. 'lo, L..OHlII, SURATlLLI, SCHIPPMAN, BlOWN &: CALHOON, P.C, Suml0l "9'0 IJloftufTOWN ....lAD H.ualllIUao, Ph 11110........8 1:, . ;@ . . .. ~.~ I ", -'~ 1-" ~ ~ If" t:~~ ... , ~ , ,,- '-.. 'I" J. '1 ie, ..~I , , " r J !j} -.. '" ('1 .-;) .....' (,.", () ~ s:;- ~ I J - - II . ... . .. .. I).IE . .. . . .. .. !)1.1 .. .. ;... -- ...~ j _.....".......~.....dI...."''' i'ONIJIlIlH ':N~."''''''''JIIOlIWO''''MII'tIi.-',"" , . , I.. I""'.. S....AfUlI. S(:tIInMAN, 8.UWN &: C.o\ItIlH)N, PI "'''"II .fltAfll Ii 1998 lllltO.III'I.,II,r""'l MIIAII A.~ U"'IIIIUI'.Il.r,tl'IW'IU!\ ,l.~.Y . c. The parties shall alternate the following holidays: Easter, Memorial Pay, Fourth of July, Labor Pay, Thanksgiving and New Year's Eve with Mother having Easter 199B. The pick up and drop off times shall be as mutually agreed to by the parties 4. Father shall be responsible for picking up the child at the beginning of his periods of partial custody and Mother shall be responsible for picking up the child at the beginning of her periods of partial custody. 5. The parties shall, at all times, foster a positive, meaningful and loving relationship between the child and the other parent, and neither parent shall say or do anything which would cast the other parent in an unfavorable or negative light to the child, it being specifically agreed that neither parent shall make any, detrimental or disparaging comments about the other parent to the child or in the presence of the child that would in any way denigrate the other parent. 6. Both parents will attempt, by all possible means, to foster the child's relationship with the other parent. Both parents realize and appreciate that it is critical for the child's health and development that the child feels good about and loving towards both parents and that both parents play a major role in helping to achieve this goal. VB. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 5293 CIVIL 1997 CIVIL ACTION - LAW . RALPH EBERT MOWERY, II, Plaintiff MICHELLE M. MOWERY, Defendant CUSTODY STIPULATION AND NOW, come the above-named parties, Ralph Ebert Mowery, II, by and through his attorney, Lori K. Serratelli, Esquire, and Michelle M. Mowery, who is unrepresented, and hereby stipulate and agree to the following provisions for custody of their minor child, Devin E. Mowery, born April 4, 1996: 1. The parties shall have shared legal custody of the child. 2 The parties shall have shared physical custody of the child. The parties shall alternate weekly (7 days) periods of partial custody on a seven days on seven days off basis, commencing with Plaintiff having the child Monday, March 9, 1998, at 6:00 p.m. until Monday, March 16, 1998, at 6:00 p.m. 3 with respect 'to holidays: A. Mother shall be entitled to have the child Mother's Day; Father shall be entitled to have the child Father's Day at times mutually agreed upon by the parties. B. The Christmas Holiday shall be divided in segments and alternated yearly with Mother having Segment A (December 24 at Noon to December 25 at noon) for 1998 and Father having Segement B (December 25 at noon to December 26 at noon) . c. The parties shall alternate the following holidays: Easter, Memorial Day, Fourth of July, Labor Day, Thanksgiving and New Year's Eve with Mother having Easter 1998. The pick up and drop off times shall be as mutually agreed to by the parties 4. Father shall be responsible for picking up the child at the beginning of his periods of partial custody and Mother shall be responsible for picking up the child at the beginning of her periods of partial custody. 5. The parties shall, at all times, foster a positive, meaningful and loving relationship hetween the child and the other parent, and neither parent shall say or do anything which would cast the other parent in an unfavorable or negative light to the child, it being specifically agreed that neither parent shall make any detrimental or disparaging comments about the other parent to th~ child or in the presence of the child that would in any way denigrate the other parent. 6. Both parents will attempt, by all possible means, to foster the child's relationship wit.h the other parent. Both parents realize and appreciate that it is critical for the child's health and development that the child feels good about and loving towards both parents and that both parents play a major role in helping to achieve this goal. ~ ,,, oil ."t~~ ~ ~ ,... J\ \ -, r'; I:; ~;..;. .. r.~ ",' ~ ' I~~ i (.~ ( ,r. ' , , ~ f1 \.' '::'. \J~ ~ ' ' L._ ~J: " \ ' ~\ f " I() .'r', ~ ~ 'V, .\. ~ ,.,1. '" . .._1 LJ'I r.o ~ I " ,,', ' t ~ ~: . I., V. "l.., ~ LL r- ') (,J <7' U ~ ~. J ~ ~ ~i~: il ),,"00"' 8 ~" . ~ ~::. !i51 J~~: ~ ~ ~~ J " " , ' _..U..AI_".'lI..WI......~" "OIlIlIWCN ':)\1 'WlIIIOl1.........w.a", 110 NOIIWa W'1WtI1Ii'Al'T'I'f ,- . l",,: . l..O."u, SIUATlLLI, SCHI"MAN, BlOWN Ie CALHOON, P.C, .'"m106 1p40 .....,ul"_l""" HAu.1Ilv!W.,A 11ho.9+45 (jEP 2 8 1991 , .' RALPH IBERT MOWIRY, II, Plaintiff VS. : : I : : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 97.'i,J, ".j (l.<<,J 'r<<~ CIVIL ACTION - LAW MICHILLE M. MOWIRY, Defendant CUSTODY CUSTODY COMPLAINT TO THE HONORABLE, THE JUDGES OF SAID COURT: i. The Plaintiff is Ralph Ebert Mowery, II, who currently resides at 34 East Main Street, Newville, Cumberland County, Pennsylvania 17241. 2. The Defendant is Michelle M. Mowery, who currently resides at 74 East Main Street, Newville, Cumberland County, Pennsylvania 17241. 3. Plaintiff seeks shared physical custody and shared legal custody of the parties' minor child, Devin E. Mowery, born April 4, 1996. 4. The child was not born out of wedlock. 5. The child is currently in the custody of the Defendant who resides at 74 East Main Street, Newville, Cumberland County, Pennsylvania. 6. During the past year the child has resided with the following persons and at the following addresses: P,rsons Address Dates Ralph Ebert Mowery, II Michelle M. Mowery Amber Marpoe Timothy Marpoe Michelle M. Mowery Amber Marpoe Timothy Marpoe 7. The father of the child is Ralph Ebert Mowery, II, who 74 East Main Street Newville, PA 17241 4-4-96 to 5-96 74 East Main street Newville, PA 17241 5-96 to present currently resides at 34 East Main street, Newville, Cumberland County, Pennsylvania. 8. The relationship of Pleintiff, Ralph Ebert Mowery, II to the child is that of father. The Plaintiff currently resides with Marie Bitner, friend, and Michael Bitner, friend. 9. The relationship of Defendant to the child is that of mother. The Defendant currently resides with the child and the persons listed in Paragraph 6 above. 10. Plaintiff has not participated as a party, witness, or otherwise in litigation concerning the custody of the said child. 11. Plaintiff has no information of a custody proceeding concerning the child pending in a Court of this Commonwealth. 12. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child.