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the children that could reasonably be expected to be of concern
to the other. Day-to-day decisions shall be the responsibility
of the party then having physical custody. With regard to any
emergency decisions which must be made, the party having physical
custody of the children at the time of the emergency shall be
permitted to make any immediate decisions necessitated thereby.
However, that party shall inform the other of the emergency and
consult with him or her as soon as possible. Each party shall be
entitled to complete and full information from any doctor,
dentist, teacher, professional or authority and to have copies of
any reports given to either party.
3. That the father of the minor children, CARL H. SHAVER,
JR., shall have such rights of temporary physical in accordance
with the following schedule:
a. Every other weekend from Friday evening at 5:00
P.M. until Sunday at 5:00 P.M.
b. Every other holiday from 9:00 A.M. until 8:00 P.M.
The holidays shall include: Easter, Memorial Day, Fourth of
July, Labor Day, and Thanksgiving. The holiday schedule will
always take priority over the regular weekly visitation schedule.
c. The Christmas holiday will be divided into two
segments. Segment A will begin on Christmas Eve at 12:00 P.M. and
will end on Christmas Day at 12:00 P.M. Segment B will begin on
Christmas Day at 12:00 P.M. and will end on December 26, at 12:00
P.M. Father shall have Segment A in 1998 and in all subsequent
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5. That the parties desire that said stipulation be entered
as an Order of Court.
WHEREFORE, Plaintiff respectfully requests that Your
Honorable Court enter an Order pursuant to the attached
stipulation.
Respectfully submitted
/'_~../ t A..A'
CHARLES C. PETRIE
3528 Bridoan Street
Harrisburg, PA 17111
(717) 561-1939
Attorney for Plaintiff
2210 Spring Run Drive, Mechanicsburg, PennsYlvania; from
Spetember, 1997, until the present, Joshua has resided with
Plaintiff at P.O. Box I, Etters, Pennsylvania.
The mother of the children is TANYA J. RIDER, who currently
resides at P.O. Box I, Etters, Pennsylvania. She is not married.
The father of the child is CARL H. SHAVER, JR., who
currently resides at 2210 Spring Run Drive, Mechanicsburg,
Pennsylvania. He is not married.
4. The relationship of the Plaintiff to the children is
that of mother. The Plaintiff currently resides with the
children and with her boyfriend, Galen Krone.
5. The relationship of the Defendant to the children is
that of father. He currently resides with his wife, Evelyn
Shaver and her two daughters, Cortney and Ashley.
6. The Plaintiff has not participated as a party or
witness, or in another capacity, in other litigation concerning
the custody of the children in this or in another court.
The Plaintiff has no information of a custody proceeding
concerning the custody of the children in this or in another
court.
Plaintiff does not know of a person not a party to these
proceedings who has physical custody of the children or who
claims to have custody or visitation rights with respect to the
children.
2. It is the intention of the pnrti')1I IIlId tho pilrtloll il<)rOO
that they will share joint legal custody of tholr mlllor
children. The parties agree that major doci:JlolIlI cOllcornllH) tho
children, including, but not necessarily limitod to, tho
children's health, welfare, education, ruligioun training and
upbringing shall be made by them jointly, nftor dincuosion ilnd
consultation with each other, with a viow toward obtaining and
following a harmonious policy in tho chlldron'n bost intorests.
Each party agrees not to impair the other party's right to shared
legal custody of the children. Each party agrees not to attempt
to alienate the affections of the children from the other party
nor to permit any third person to attempt to so alienate the
affections of the children from the other pnrty. Each party
shall notify the other of any activity or circumstance concerning
the children that could reasonably be expected to be of concern
to the other. Day-to-day decisions shall be the responsibility
of the party then having physical custody. With regard to any
emergency decisions which must bo made, the party having physical
custody of the children at the time of the emergency shall be
permitted to make any immediate decisions necessitated thereby.
However, that party shall inform the other of the emergency and
consult with him or her as soon as possible. Each party shall be
entitled to complete and full information from any doctor,
dentist, teacher, professional or authority and to have copies of
any reports given to oither party.
(,
3. That the father of the minor children, CARL H. SHAVER,
JR., shall have such rights of temporary physical in accordance
with the following schedule:
a. Every other weekend from Friday evening at 5:00
P.M. until Sunday at 5:00 P.M.
b. Every other holiday from 9:00 A.M. until 8:00 P.M.
The holidays shall include: Easter, Memorial Day, Fourth of
July, Labor Day, and Thanksgiving. The holiday schedule will
always take priority over the regular weekly visitation schedule.
c. The Christmas holiday will be divided into two
segments. Segment A will begin on Christmas Eve at 12:00 P.M. and
will end on Christmas Day at 12:00 P.M. Segment B will begin on
Christmas Day at 12:00 P.M. and will end on December 26, at 12:00
,
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P.M. Father shall have Segment A in 1998 and in all subsequent
even numbered years. Mother shall have Segment A in 1999 and in
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all subsequent odd numbered years.
d. At such other times as the parties shall agree.
4. Both parties shall be entitled to three (3) weeks
vacation each year with the minor children. This period of
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visitation does not have to run consecutively. It is understood
that one (1) week shall consist of seven (7) days. Each party
shall provide the other party with thirty (30) days' notice of
their intent to utilize this period of visitation.
5. Defendant retains the right to claim Joshua as a
dependent for his 1997 Income Tax purposes. Plaintiff shall
claim both children as exemptions for Federal Income Tax purposes
for 199B and in each subsequent year.
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WITNESS