HomeMy WebLinkAbout98-01019
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PATRICIA L.IIANN,
IN TilE COURT OF COMMON PLEAS QIt'
CUMBERLAND COUNTY
Plaintiff
vs
CIVIL ACTION - LAW
NUMBER: QP ',/of? CIVIL TERM
IN CUSTODY
BRUCE E.IIANN,
Defendant
STIPULATION AND AGREEMENT
COME NOW, the Plaintiff, PATRICIA L. "ANN, by and through her counsel, Sally J,
Winder, and the Defendant, BRUCE E. "ANN, and do stipulate and agree as follows:
I. The parties are the natural parents of two minor children, JANEEN N. "ANN,
born April 12, 1988, and DEVON R. "ANN, born January 17, 1994,
2. The two minor children, JANEEN N. "ANN and DEVON R. "ANN are currently
residing with the Plaintiff, PATRICIA L. "ANN, at 172 Kline Road, Shippensburg, Cumberland
County, PeMsylvania, where they have resided since May 1997,
3, The parties agree that mother, PATRICIA L. "ANN, is capable of caring for the
minor children and has been caring for the children,
4, The parties agree that primary physical and residential custody of the minor children,
JANEEN N. "ANN and DEVON R. "ANN, shall be awarded to mother, PATRICIA L. MANN,
5, Father, BRUCE E. "ANN shall be entitled to certain rights of partial custody and
visitation with the minor children on weekends from 11 :00 o'clock A.M. on Saturday until 07:30
o'clock P,M, on Sunday, Additionally, father shall have the children on Christmas Eve of each year
and on Easter of each year,
6, The parties agree that the minor children shall be with mother on Christmas Day
each year and mother on Thanksgiving Day each year,
7, Father shall also be entitled to two (02) weeks of partial custody of the children
during the summer months, not to interfere with the school schedule, These weeks may be taken
consecutively or separately, but in any case, father shall provide mother at least one (01) week
advance notice,
8, Father shall also have partial custody and visitation with the minor children at such
other times as may be mutually agreed upon between the parties, Mother shall not unreasonably
withhold visitation or partial custody,
9, The parties agree that this Stipulation and Agreement may be entered as an Order by
the Court without the necessity of their presence in Court,
IN WITNESS WHEREOF, the parties hereto, and each of them intending to be legally
bound hereby, have hereunto set their hands and seals this 7...dt\ day of ~~, 1998,
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PATRICIA L. HANN
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BRUCE E, HANN
(SEAL)
(SEAL)
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