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HomeMy WebLinkAbout03-0396AMBER L. HILTZ, BRIAN D. HILTZ, Petitioner Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: d2PJ~ 3~'~ CIVIL ACTION - LAW CUSTODY PETITION FOR CUSTODY AND NOW, this '~;.~1,, day of January, 2003, comes the Petitioner, AMBER L. HILTZ, by an through her attorneys, the Law Offices of BATURIN & BATURIN, and files this Petition For Custody and respectfully represents as follows: 1. The Petitioner is, AMBER L. HILTZ, an adult individual, sui juris, who currently resides at 6412 Carlisle Pike, Lot 13, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 2. The Respondent is BRIAN D. HILTZ, an adult individual, sui juris, who currently resides at 6412 Carlisle Pike, Lot 13, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 3. Petitioner and Respondent are married, having been married on March 2, 1998, in Winchester, Frederick County, Virginia, and have recently separated. 4. The Petitioner and Respondent are the natural parents of one minor child, KELSEY M. HILTZ, presently three (3) years of age, bom on March 8, 1999. Said minor child is the subject of this Custody Petition. 5. The aforementioned minor child is presently in the physical custody of her Natural Mother, the Petitioner, in the Custody Petition, and resides at 6412 Carlisle Pike, Lot 13, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 6. The parties hereto, intending to be legally bound hereby, covenant and agree as follows: a) The Natural Mother shall have primary legal custody of the parties' minor child, KELSEY M. HILTZ. The parties agree that the Natural Mother shall have primary physical custody of the parties' child and the Natural Father shall have periods of visitation as set forth below: b) Every other consecutive Saturday and Sunday for four (4) hours each day. Said period of visitation shall take place at a public location at a time agreed upon by the parties. c) All transportation is to be provided by the Natural Mother. d) Natural Father shall have additional periods of visitation at times reasonably agreed upon by the parties hereto at a later date. e) During Natural Father's periods of visitation, Natural Father shall visit with the child at a public location unless prior consent is given by Natural Mother one (1) week in advance. f) During Natural Father's periods of visitation, Natural Father shall visit with the child under the supervision of the Natural Mother should natural mother deem it necessary. g) Natural Father is not to associate with any of paramours during his periods of vistiation with the minor child unless natural father has remarried and natural mother has had an oppodunity to meet and foster a relationship for the benefit of the minor child. h) At all times that either party has physical custody of said child, the parties, to the best of their ability, shall shield and protect the child from any third party's use of alcohol. i) At all times that either party has physical custody of said child, the parties, to the best of their ability, shall refrain from making derogatory remarks in front of the minor child. j) This Order is entered pursuant to an agreement of the parties hereto. The parties may modify the provisions of this Order by mutual agreement. In the absence of mutual agreement, the terms of this Order shall control. k) It is the intent of the parties hereto to become and remain legally bound by the mutual promises and covenants herein contained. I) This agreement shall be construed under the laws of the Commonwealth of Pennsylvania. m) It is further understood that this Stipulation is to go into effect immediately. n) This Stipulation is entered into pursuant to the mutual understanding and agreement of the parties hereto and it is the intent of both to become and remain legally bound by the mutual promises and covenants herein contained. o) The parties hereto declare that each of them fully understands the covenants and provisions contained in this Agreement. The parties acknowledge having the opportunity to receive counsel and advice from an attorney of his or her choice regarding all of his or her legal rights, duties, VERIFICATION I VERIFY THAT THE STATEMENTS MADE IN THIS PETITION ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, BELIEF, AND INFORMATION. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 PA.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. z AMBER L. HILTZ, BRIAN D. HILTZ, Petitioner Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this day ~, 2003, upon presentation of the Petition For Custody in connection with the above-captioned matter, it is hereby ORDERED AND DECREED that the executed Stipulation dated January 21, 2003, become an Order of Court. AMBER L. HILTZ, BRIAN D. HILTZ, Petitioner Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CUSTODY STIPULATION FOR CUSTODY AND NOW, this :~gk, day of January, 2003, the Petitioner, AMBER L. HILTZ, and Respondent, BRIAN D. HILTZ, agree to the following Stipulation For Custody: 1. The Petitioner is AMBER L. HILTZ, an adult individual, sui juris, who currently resides at 6412 Carlisle Pike, Lot 13, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 2. The Respondent is BRIAN D. HILTZ, an adult individual, sui juris, who currently resides at 6412 Carlisle Pike, Lot 13, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 3. Petitioner and Respondent are married, having been married on March 2, 1998, in Winchester, Frederick County, Virginia, and have recently separated. 4. The Petitioner and Respondent are the natural parents of one minor child, KELSEY M. HILTZ, presently three (3) years of age, born on March 8, 1999. Said minor child is the subject of this Custody Stipulation. 5. The aforementioned minor child is presently in the physical custody of her Natural Mother, the Petitioner in the Custody Petition, and resides at 6412 Carlisle Pike, Lot 13, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 6. The parties hereto, intending to be legally bound hereby, covenant and agree as follows: a) The Natural Mother shall have primary legal custody of the parties' minor child, KELSEY M. HILTZ. The parties agree that the Natural Mother shall have primary physical custody of the parties' child and the Natural Father shall have periods of visitation as set forth below: b) Every other consecutive Saturday and Sunday for four (4) hours each day. Said period of visitation shall take place at a public location at a time agreed upon by the parties. c) All transportation is to be provided by the Natural Mother. d) Natural Father shall have additional periods of visitation at times reasonably agreed upon by the parties hereto at a later date. e) During Natural Father's periods of visitation, Natural Father shall visit with the child at a public location unless prior consent is given by Natural Mother one (1) week in advance. f) During Natural Father's periods of visitation, Natural Father shall visit with the child under the supervision of the Natural Mother should natural mother deem it necessary. g) Natural Father is not to associate with any of paramours during his periods of vistiation with the minor child unless natural father has remarried and natural mother has had an opportunity to meet and foster a relationship for the benefit of the minor child. h) At all times that either party has physical custody of said child, the parties, to the best of their ability, shall shield and protect the child from any third party's use of alcohol. i) At all times that either party has physical custody of said child, the parties, to the best of their ability, shall refrain from making derogatory remarks in front of the minor child. j) This Order is entered pursuant to an agreement of the parties hereto. The parties may modify the provisions of this Order by mutual agreement. In the absence of mutual agreement, the terms of this Order shall control. k) It is the intent of the parties hereto to become and remain legally bound by the mutual promises and covenants herein contained. I) This agreement shall be construed under the laws of the Commonwealth of Pennsylvania. m) It is further understood that this Stipulation is to go into effect immediately. n) This Stipulation is entered into pursuant to the mutual understanding and agreement of the parties hereto and it is the intent of both to become and remain legally bound by the mutual promises and covenants herein contained. o) The parties hereto declare that each of them fully understands the covenants and provisions contained in this Agreement. The parties acknowledge having the opportunity to receive counsel and advice from an attorney of his or her choice regarding all of his or her legal rights, duties, obligations and liabilities in connection with, or resulting from, this Agreement. Each party has executed this Agreement freely and voluntarily. IN WITNESS WHEREOF, the Petitioner and Respondent have set their hands and seals the day and year first above written. WITNESS: R L. HILTZ, Natural Mother(~ BRIAN D. HILYZ, Natural Father (SEAL)