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LAW ClITKl::i
MARLIN H. McCALEfJ
follows:
1. SEPARATION. It shall be lawful for each party at all
times hereafter to live separate and apart from the other
party, at such place or places as he or she from time to time
may chose or deem fit.
2. NONINTERFERENCE. Each party shall be free from
interference, authority and control, direct or indirect, by the
other in all respects as fully as if he or she were single and
unmarried. Each may, for his or her separate use or benefit,
conduct, carryon and engage in any business, occupation,
profession or employment which to him or her may seem
advisable. Neither party shall molest, harass, disturb or
malign the other or the family of said other, nor compel or
attempt to compel the other to cohabit or dwell with him or
her.
3. MUTUAL RELEASE. Husband relinquishes his inchoate
intestate right in the estate of Wife, and Wife relinquishes
her inchoate intestate right in the estate of Husband, and each
of the parties hereto by these presents, for himself or
herself, his or her heirs, executors, administrators or
assigns, does remise, release, quitclaim, and forever discharge
the other party hereto, his or her heirs, executors,
administrators or assigns, or any of them, of and from any and
all claims, demands, damages, actions, causes of actions, or
suits at law or in equity, of whatsoever kind or nature, for or
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I.AW IlITICJ::i
MAIlLIN n. M[CAl.EB
because of any matter or thing done, omitted, or suffered to be
done by said party prior to and including the date hereof;
except that this release shall in no way exonerate or discharge
either party hereto from the obligations and promises made and
imposed by reason of this Agreement, and shall in no way affect
any cause of action in absolute divorce which either party may
have against the other party.
4. MARITAL PROPERTY. The parties hereto acknowledge and
agree that they acquired no real estate during their marriage,
but they did acquire various items of personal property,
including household goods, contents, furniture and furnishings
and bank accounts, whether the same were held jointly or
individually by the parties hereto. In addition, the parties
acquired a 1987 Oldsmobile Cutlass automobile (titled jointly
to the parties), a 1974 Ford Gran Torino automobile (titled
only to Wife) and a 1963 Chevrolet truck (titled jointly to the
parties), all of which are free and clear of liens and
encumbrances and all of which are in the possession of Husband.
The parties covenant and agree that they have heretofore
divided between themselves all such items of personal property
in the manner to which both agree. In addition, Wife purchased
a 1974 Pontiac Grand Am automobile subsequent to the date of
separation, which is titled in her name only and is in her
possession. Each of the parties hereto hereby relinquishes and
disclaims any and all right, title and interest in and to any
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items of personal property now in the possession of the other,
and each covenants and agrees that the other shall be and
remain the sole and separate owner of said items of personal
property, regardless of whether the same was heretofore owned
jointly or individually by the parties hereto. In furtherance
hereof, the parties agree to execute any assignments of title
to the other necessary to transfer title to each vehicle as set
forth above.
In addition. notwithstanding the foregoing provisions of
this paragraph, Husband assigns, transfers and conveys unto
Wife the freezer at his residence and Husband will deliver same
to Wife within sixty (60) days after the execution of this
Agreement.
5. RETIREMENT BENEFITS. Husband relinquishes and
disclaims any and all right, title, interest or entitlement in
and to any and all of Wife's retirement and/or pension benefits
heretofore arising from whatsoever source, and Wife
relinquishes and disclaims any and all right, title, interest
or entitlement in and to any and all of Husband's retirement
and/or pension benefits heretofore arising from whatsoever
source, and each party covenants and agrees that all such plans
and benefits of each party shall be and remain the sole and
separate property of that party.
6. INDEMNIFICATION FOR PAST DEBTS. Except as provided in
Paragraph 4, above, each of the parties hereto covenants and
LAW OITleei
MAIlLlN R McCM.EB
agrees to assume full responsibility for and to pay all debts
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and obligations of whatsoever kind or nature incurred
individually by that party prior to the day and date of this
Agreement, and each of the parties hereto hereby covenants and
agrees to indemnify the other party and save him or her
harmless from all liability or claim on account of said debts
and obligations from and after the date hereof.
7. FUTURE OWNERSHIP OF PROPERTY. Each of the parties
hereto may hereafter own and enjoy, independently of any claims
or rights of the other, all items of personal and real
property, tangible or intangible, hereafter acquired by him or
her, with full power in him or her to dispose of the same as
fully and effectively in all respects and for all purposes as
though he or she were unmarried.
B. MUTUAL RELEASES. The parties acknowledge that under
prevailing Pennsylvania law they each have certain possible
fiscal rights, including but not limited to the following:
spousal support, alimony pendente lite in the event of a
divorce, permanent alimony subsequent to a divorce, recovery of
counsel fees, costs and expenses in the event of a divorce, and
equitable distribution of marital property, as well as the
right to seek discovery of assets through interrogatories
and/or depositions. It is the intention of the parties hereto
that all of the foregoing rights and remedies are hereby waived
and forever released and that this Agreement shall have the
effect of a final Order of Court relieving each party of the
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obligation to the other for any and all of the foregoing
possible rights and remedies. Specifically, both parties
covenant and agree that: both waive, release and forever
relinquish their respective possible right of spousal support
of, from and against the other party; neither party will at any
time seek alimony pendente lite, alimony, counsel fees, costs
or expenses from the other party; and the parties have effected
an equitable distribution of their marital property and neither
will seek further distribution by any action at law or in
equity.
9. EFFECT OF DIVORCE DECREE. The parties covenant and
agree that unless otherwise specifically provided herein, this
Agreement shall continue in full force and effect after such
time as a final decree in divorce may be entered with respect
to the parties.
10. INDEMNIFICATION FOR FUTURE DEBTS. Each of the parties
hereby covenants and agrees with the other party not to make,
incur or attempt to make or incur any debt or obligation for or
on behalf of the other party hereto, or for which the other
party may be held liable, from and after the date hereof, and
each of the parties hereto hereby covenants and agrees to
indemnify the other party and save him or her harmless from all
liability or claim on account of said debt or obligations from
and after the date hereof.
l.AWmnu:',
MAflUN Ie. McCAI.(~U
11. OTHER DOCUMENTS. Each of the parties hereto shall,
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l.AW IJff'ICES
MARLIN n. McCALEB
competent jurisdiction, all other provisions shall nevertheless
continue to be in full force and effect.
14. LAW OF PENNSYLVANIA APPLICABLE. This Agreement shall
be construed under the laws of the Commonwealth of
Pennsylvania.
15. ADVICE OF COUNSEL. Both parties covenant and agree
that they have had ample and sufficient time to carefully and
fully review the terms and provisions of this Agreement and to
seek and obtain the advice and counsel of an attorney with
respect to the same. Wife has engaged the services of
Elizabeth B. Stone, Esquire, and Husband has engaged the
services of Marlin R. McCaleb, Esquire. Both parties covenant
and agree that they fully understand the facts upon which this
Agreement is premised and based, that they believe this
Agreement to be fair and equitable, that said Agreement is
being entered into freely and voluntarily by each of them, and
that the execution of this Agreement is not the result of any
duress or undue influence and that it is not the result of any
collusion or improper or illegal agreement or agreements.
16. INTEGRATION. This Agreement constitutes the entire
understanding between the parties and supersedes any and all
prior agreements and negotiations between them. Both parties
further agree that there are no covenants, conditions,
representations or agreements, oral or written, of any nature
whatsoever, other than those contained herein.
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DONNA M. CONRAD, . IN THE COURT OF COMMON PLEAS OF
.
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
.
.
v. NO. 98 - 866 CIVIL TERM
.
.
WAYNE R. CONRAD,
Defendant CIVIL ACTION IN DIVORCE
MOTION TO INCORPORATE AGREEMENT
INTO DECREE IN DIVORCE
Donna M. Conrad, plaintiff in the above action, by her attorneys,
STONE LaFAVER & SHEKLETSKI, moves that your Honorable Court incorpo-
rate the attached agreement dated September 8, 1998, into the Decreee
in Divorce.
STONE LaFAVER & S
By
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PRAECIPE TO TRANSMIT RECORD
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To the Prothonotary:
Transmit the record. together with the following information to
the court for entry of a divorce decree:
1. Ground for divorce: irretrievable breakdown under S3301(c)
~~i~t of the Divorce Code. (Strike out inapplicable section).
2. Date and manner of service of the complaint: Feb. 20, 1998, U.S.
Certified Mail, restricted delivery, postage prepaid
3. Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent
by S3301(c) of the Divorce Code: by plaintiff Sept. 11, 1998
by defendant Sept. 8, 1998
(b)(l) Date of execution of the
required
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!03301(d)
and ~
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of the Divorce Code:
affidavit required by
; (2) Date of filing
service of the plaintiff's affidavit upon the r~spondent:
4. Related claims pending:
ALL CLAIMS SETTLED
5. Complete either (a) or (b).
(a) Date and manner of service of the notice of intention to
file praecipe to transmit rccor.d. a copy of which is attached:
(b) Date plaintiff's Waiver of Notice in S330l(c) Divcrce was
filed with the Prothonctary: ~p~?tA l'(.q)~
Date defendant's waiver of Notice in S330l(c) Divorce was
filed with the Prothonotary: I B
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DONNA M. CONRAD,
PLaintiff/Resp~ndent
v.
IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. q[' ./'(,.(,.. (J,c.'l'/'if'ru.\
WAYNE R. CONRAD,
Defendant/Petitioner
CIVIL ACTION
CUSTODY
ORDER OF COURT
AND NOW, this
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day of \'-c.-t-NCl "I
, 199B, upon
consideration of the attached complaint, it is hereby directed that
the parties and their respective counsel appear before t:Y-\,,, '(,...) ,
~\'\0.'\ ' E. S,C-\ . , thg Conciliator, at ~",J, HO\ (\ \.\~" -'
\Jc\:\-{{'kr-i.....fj.PA on t~e dl-\ day of \'--\r1.n h , 1993...,
at q; 00 , A.M., for a Pre-Hearing Custody Conference. At such
conference, an effort will be made to resolve the issues in dispute;
or if this cannot be accomplished, to define and narrow the issues to
be heard by the court, a~d to enter into a temporary order. All
children age five or older may also be present at the conference.
Failure to appear at the conference may provide grounds for entry of a
temporary or permanent order.
FOR THE COURT,
By: ~H\'\\<S\ ~l\.HI\'\!~nl.A f~
Custody' Conciliatol() , n1>.')
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CA-~NOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
Telephone: (717) 249-3166
DONNA M. CONRAD,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 98
CIVIL TERM
WAYNE R. CONRAD,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued ~n court. If you wish to defend against the
claims set forth in the following pages, you must take prompt action.
You are warned that if you fail to do so, the case may proceed without
you and a Decree of Divorce or annulment may be entered against you by
the Court. A judgment may also be entered against you for any other
claim or relief requested in these papers by the plaintiff. You may
lose money or property or other rights important to you, including
custody or visitation of your children.
When the ground for the divorce is indignities or irretrievable
breakdown of the marriagn, you may request marriage counseling. A
list of marriage counselors is available in the Office of the
Prothonotary at the Cumberland County Courthouse, Carlisle, PA 170l3.
IN YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LO:;E THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER on CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
LEGAL HELP.
Cumberland Countv Bar Association
2 Libertv Avenue
Carlisle. PA 17013
Telephone: (7171 249-3166
fl\dlv\conrad.com\2.90
DONNA M. CONRAD, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
.
. 98 - fG,b
v. NO. CIVIL TERM
WAYNE R. CONRAD, . CIVIL ACTION LAW
.
Defendant IN DIVORCE
COMPLA!NT IN DIVORCE AND CUSTODY
I. The Plaintiff in this action is Donna M. Conrad, an adult
individual, who currently resides at 110 N. Walnut Street, Mechanics-
burg, Cumberland County, Pennsylvania 17055.
2. The Defendant in this action is Wayne R. Conrad, an adult
individual, who currently resides at 602 E. Coover Street, Mechanics-
burg, Cumberland County, Pennsylvania 17055.
3. Both the Plaintiff and the Defendant have been bona fide
residents of the Commonwealth of Pennsylvania for at least six (6)
months immediately previous to the filing of this complaint.
4. The Plaintiff and Defendant were lawfully joined in marriage
on July 28, 1989, in Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment
between the parties hereto in this or any other jurisdiction.
6. The Plaintiff avers as the grounds upon which this action is
based is that the marriage between the parties hereto is
irretrievably broken.
7. There was one child born of the marriage.
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B. The Plaintiff harl been advised that counseling is available
and that the Plaintiff may have the right to request that the court
require the parties to participate in counseling.
9. The Plaintiff requests the court to enter a decree of
divorce.
COUNT I - ALIMONY AND ALIMONY PENDENTE LITE
10. The prior paragraphs of this complaint are incorporated
herein by reference thereto.
II. The plaintiff, Donna M. Conrad, date of birth March 21,
1956, currently lives at 110 North Walnut Street, Mechanicsburg,
Cumberland County, Pennsylvania 17055. The defendant, Wayne R.
Conrad, date of birth September 2, 1948, currently resides at 602 East
Coover Street, Mechanicsburg, Cumberland County, Pennsylvania 17055.
12. The plaintiff, Donna M. Conrad, requires reasonable support
and alimony to adequately maintain herself in accordance with the
standard of living established during the marriage.
13. The plaintiff, Donna M. Conrad, requests the Court to allow
alimony and alimony pendente lite as it deems reasonable pursuant to
Sections 3701 and 3702 of the Pennsylvania Divorce Act.
COUNT !I - COMPLAINT FOR CUSTODY
14. The prior paragraphs of this complaint are incorporated
herein by reference thereto.
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IS. The plaintiff i~, DONNA M. CONRAD, an adult individual,
residing at 110 North Walnut street, Mechanicsburg, PA 17055.
16. The defendant is WAYNE R. CONRAD, an adult individual,
residing at 602 E. Coover street, Mechanicsburg, PA 17055.
17. Plaintiff seeks primary physical custody of BRANDON RICHARD
CONRAD who resides at 110 North Walnut Street, Mechanicsburg, PA
170S5, is seven (7) years of age having been born on January 8, 19911
The child was not born out of wedlock.
The child is presently in the custody of his mother, the
Plaintiff above-named, Donna M. Conrad, and his father, the defendant,
Wayne M. Conrad.
The plaintiff seeks primary physical custody of the child,
Plaintiff agrees to shared legal custody of the minor child with the
defendant enjoying liberal minority physical custody.
During the past five years, the child has resided with the following
persons and at the following addresses:
NAME
ADDRESS
DATES
Donna M. Conrad and
Wayne M. Conrad
same
602 E. Coover Street
Mechanicsburg, PA 17055
2317 Camby Street
Harrisburg, PA
9/94 -
1998
1-9-91 -
9/94
The mother of the child is the plaintiff, Donna M. Conrad,
currently residing at 110 North Walnut Street, Mechanicsburg, PA
170SS.
She and the Defendant are husband and wife.
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The father of the child is the defendant, Wayne R. Conrad,
currently residing at 602 E. Coover Street, Mechanicsburg, PA 17055,
He is married to the plaintiff.
lB. The relationship of plaintiff to the child is that of
mother. The plaintiff currently resides with the following persons:
NAME
RELATIONSHIP
Preston C. Miller
Alexis Miller
Brooke Bender
friend
Miller's daughter
Plaintiff's daughter
19. The relationship of defendant to the child is that of
father. The defendant currently resides with the following persons:
NAME
RELATIONSHIP
Bryan Conrad (currently in jail)
Tracey Maxwell
Dillon Conrad
Mandy Conrad
Defendant's son
Defendant's son's
girlfriend
Defendant's grandson
Defendant's niece
20. Plaintiff has not participated as a party or witness, or in
another capacity, in other litigation concerning the custody of the
child in this or another court.
Plaintiff has no information of a custody proceeding
concerning the child pending in a Court of this Commonwealth,
Plaintiff does not know of a person not a party to the
proceedings who has physical custody of the minor child or claims to
have custody or visitation rights with respect to the child.
21. The best interest and permanent welfare of the minor child
will be served by granting the relief requested because:
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(a) The child have resided with his mother since birth who
has provided a continuous living relationship with the child;
(b) The mother is able to provide a stable home and family type
environment for the child allowing the child opportunity to spend time
with the child's father consistent with a schedule the parties have
arranged between themselves,
22. Each parent whose parental rights to the child have not been
terminated and the person who has physical custody of the child have
been named as parties to this action.
WHEREFORE, plaintiff respectfully requests that this court grant
the plaintiff physical majority custody of the child with shared legal
custody to the defendant, giving the defendant liberal minority
physical custody,
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I verify that the statements made in this complaint are true and
correct. I understand that false statements herein are made subject
to the penalties of 18 P.C.s. S4904, relating to unsworn falsification
to authorities.
t..a')'//}10 In r;~l./7Cl"i
DONNA M. CONRAD
Date:
,:1..../2--"}8
STONE LaFAVER & STONE
By
ELIZAB B.
Attorney at
Supreme Court ID #60251
414 Bridge Street, P.O. Box E
New Cumberland, PA 17070
Telephone 717-774-7435
Attorneys for Plaintiff
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DONNA M, CONRAD,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 9B - B66 CIVIL TERM
v,
.
.
WAYNE R. CONRAD,
Defendant
: CIVIL ACTION - IN DIVORCE
AFFIDAVIT OF CONSENT
I. A complaint in divorce under S 3301(c) of the Divorce Code
was filed on February 13, 199B.
2. The marriage of plaintiff and defendant is irretrievably
broken and ninety (90) days have elapsed from the date of filing the
complaint and service of the complaint.
3. I consent to the entry of a final decree of divorce after
service of notice of intention to request entry of the decree.
4. I understand that I may lose rights concerning alimony,
division of property, lawyer's fees or expenses if I do not claim them
before a divorce is granted.
I verify that the statements made in this affidavit are true and
correct. I understand that false statements herein are made subject
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,
to the penalties of IB Pa, C.S. S 4904 relating to unsworn falsifica-
tion to authorities.
, .
S?07 II ';g
Date I
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DONNA M. CONRAD, Plaintiff
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DONNA M. CONRAD, : IN THE COURT OF COMMON PLEAS OF
Plaintiff . CUMBERALND COUNTY, PENNSYLVANIA
.
:
v. . NO. 98 - 866 CIVIL TERM
.
WAYNE R. CONRAD, . CIVIL ACTION IN DIVORCE
.
Defendant .
.
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF DIVORCE DECREE UNDER S 3301(c) OF THE DIVORCE CODE
I. I consent to the entry of a final decree of divorce without
notice.
2, I understand that I may lose rights concerning alimony,
division of property, lawyer's fees or expenses if I do not claim them
before a divorce is granted.
3. I understand that I will not be divorced until a divorce
decree is entered by the Court and that a copy of the decree will be
sent to me immediately after it is filed with the Prothonotary.
I verify that the statements made in this affidavit are true and
correct. I understand that false statements herein are made subject
to the penalties of 18 Pa, C.S. S 4904 relating to unsworn falsifica-
tion to authorities.
(Q li')1 c. jr) ~ 11.)/7 /
DONNA M. CONRAD, Plaintiff
/
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Date: <)(/0, I, _ 1.
,. .
DONNA M. CONRAD,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 98 - 866 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
vs.
WAYNE R. CONRAD,
Defendant
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
~3301 (o) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce
without notice.
2. I understand that I may lose rights concerning alimony,
division of property, lawyer's fees or expenses if I do not
claim them before a divorce is granted.
3. I understand that I will not be divorced until a
divorce decree is entered by the Court and that a copy of the
decree will be sent to me immediately after it is filed with
the Prothonotary.
I verify that the statements made in this affidavit are
true and correct. I understand that false statements herein
are made subject to the penalties of 18 Pa. C.S. Section ~4904,
relating to unsworn falsification to authorities.
Date: 9-,'? - 99 1998
jJ ~L~ t- r!r~/~J
yne . Conrad, Defendant
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OONNA M. CONRAD,
Plaintiff/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 98-866 CIVIL TERM
CIVIL ACTION - LAW
WAYNE R. CONRAD,
Defendant/Petitioner
IN CUSTODY
OODER OF COURT
AND tool, this 3 ($ day of (Yl~
consideration of the attached Custody Conciliation
and directed as follows:
, 1998, upon
Report, it is ordered
I. The Mother, Donna M. Conrad, and the Father, Wayne R. Conrad, shall
have shared legal custody of Brandon Richard Conrad, born January 8, 1991.
Each parent shall have an equal right, to be exercised jointly with the
other parent, to make all major non-emergency decisions affecting the
Child's general well being including, but not limited to, all decisions
regarding his health, education, and religion. Pursuant to the terms of
this paragraph each parent shall be entitled to all records and information
pertaining to the Child inClUding, but not limited to, school and medical
records and information. To the extent one parent has possession of any
such records or information, that parent shall be required to share the
same, or copies thereof, with the other parent within such reasonable time
as to make the records and information of reasonable use to the other
parent.
2. The parties shall share having physical custody of the Child in
accordance with the following schedule:
A. During the school year, the parties shall alternate having
custody of the Child on weekends from Saturday at 9:00 a.m.
until Sunday at 4:30 p.m. and shall alternate having custody
after school/overnight during the week on a daily basis as
follows:
WEEK I
Saturday at 9:00 a.m. through Sunday 4:30 p.m. - Father
Sunday at 4:30 p.m. through Monday before school - Mother
Monday after school through Tuesday before school - Father
Tuesday at 4:30 p.m. through Wednesday before school - Mother
Wednesday after school through Thursday before school - Father
Thursday at 4:30 p.m. through Friday before school - Mother
Friday after school through Saturday at 9:00 a.m. - Father
WEEK II
Saturday at 9:00 a.m. through Sunday 4:30 p.m. - Mother
Sunday at 4:30 p.m. through Monday before school - Father
Monday at 4:30 p.m, through Tuesday before school - Mother
Tuesday after school through Wednesday before school - Father
Wednesday at 4:30 p.m. through Thursday before school - Mother
Thursday after school through Friday before school - Father
B. The parties shall share custody of the Child during the summer
school break under the same schedule set forth in A of this
provision with the exception that during the weekdays when the
Mother is working, the Father shall have custody of the Child.
3. The parties shall share having custody of the Child on holidays as
follows:
A. Christmas: The Christmas holiday shall be divided into
segment A, which shall run from Christmas Eve at 12:00 noon
until Christmas Day at 12:00 noon, and Segment B, which shall
run from Christmas Day at 12:oo noon until December 26 at
12:00 noon. The Mother shall have custody of the Child during
Segment A in even numbered years and during Segment B in odd
numbered years. The Father shall have custody of the Child
during Segment A in odd numbered years and during segment B in
even numbered years.
B. Thanksgiving/Easter: The Mother shall have custody of the
Child every year on Thanksgiving Day and Easter Sunday from
9:00 a.m. until 3:00 p.m. and the Father shall have custody of
the Child from 3:00 p.m. through the following morning.
C. Father's Day/Mother's Day: The Father shall have custody of
the Child every year on Father's Day from 9:00 a.m. until
termination of his period of custody under the regular weekend
custody schedule and the Mother shall have custody of the
Child every year on Mother's Day from 9:00 a.m. until
termination of her period of custody under the regular weekend
custody schedule.
4. unless otherwise agreed by the parties, the party receiving
custody of the Child shall be responsible to provide transportation for the
exchange of custody.
5. This order is entered pursuant to an agreement of the parties at a
Custody Conciliation Conference. 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.
J.
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cc:
Elizabeth B. Stone, Esquire - Counsel for Mother
Marlin R. McCaleb, Esquire - Counsel for Father -
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CUSTODY CXH:ILIATIOO SUlMARY REPCRr
,
IN ACXXJUlANCE WITH Cl.IlBERIJ\ND CXUfrY RULE OF CIVIL ~
1915.3-8, the undersigned CUstody Conciliator submits the following report:
,
1, The pertinent information concerning the Child who is the subject
of this litigation is as follows:
Brandon Richard Conrad
January 8, 1991
Mother/Father
NAME
DATE OF BIRTH
CURRENl'Ly IN CUSTODY OF
2. A Conciliation Conference was held on March 24, 1998, with the
following individuals in attendance: The Mother, Donna M. Conrad, with
her counsel, Elizabeth B. stone, Esquire and the Father, Wayne R. Conrad,
with his counsel, Marlin R. Mccaleb, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
,
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Date .
Da~~
Custody Conciliator
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