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HomeMy WebLinkAbout98-03403 I 1 1 I i J \Ii I 01 .... I \l! ~I .~ I ....; ~1 lI)j I I ~l I I I \ll -I Q;:. ~ i i I i , i I i I f'! ...1 ~! - - ~ '-J fY) '<:::) ~ l'<} 6:. C- ~ f >. " , , ,. ~..::: , , , U.I (~,~ C! , '-.;- .. 1.< L)... (,: ':':' t"::1 , IJ. , c.:,: , " ice. :.=.) '. Lt. C": -.... C) C;~ , ..' ... '. -r :8 d 11,.., " I I IIi o l(] <?' :J (;,2 J; r.9 l"'.':J 1<)- ~ ," -' / j c,- LAIt' OFFICES OF DARREll C. DETHLEFS P.O. Dux 368 3605 H.rket Street C.mpHIIl, PA 17001 ..' Tammy Lynn Steinbeiser 63 Arnold Road Enola, Pa 17025 .~.. ~.:~~~.~..~", J' : ~ -' '- ..' ~('- ~;.. - ". ,_' '~f\ ~".' .b, \ , .ry;. , " , '.~ :,.:\ I .. ~r" "'.C' . " ~ '{!':", ~ n., ~~ ~~,; " -,I~.. l: ...~;. ( ;.i,., ) '." ~'., \; -,t; ~ ~.~ .",C -,'; <11'1. '. ~..l:.~~~,.\.;. d:~ '"r- ."( !;~', - ~. "., "jl ~ ... "i.,. , ~li"'._. 'J' " ;":;; ~ 1 r~ i. t. ':1: I"", ,,'"' , ',..,1. .' -.!'t, ,. '1', ";., ." , .::". -!~1 ~. I-#.. .l ~ .. ~. ~!fdt~r ~ . 4~ I' ..,. \ \y . ,a ~I~f " '" ~. ... stiDulotion Agreement as to Custody &. Visitation On this ~q"" day of May 1998, Tammy Lynn Steinbeiser of 83 Arnold Road, Enola, Pennsylvania, hereinafter "Mother", and Cynthill D. Nale of 63 Arnold Road, Enola, Pennsyl'Jania, hereby agree to the following terms and conditions of custody and visitation of Elaine Diane Marie Steinbeiser, born April 24, 1998, hereinafter refen-ed to as "Chil d". The parties hereto recite, declare and agree as follows: 1. Tammy Lynn Steinbeiser is the natural mother of Elaine Diane Marie Steinbeiser born April 24, 199B. 2. Tammy Lynn Steinbeiser is on active duty with the United States Navy, 3. Cynthia D. Nale is the foster mother and guardian of Tammy Lynn Steinbeiser. 4. The parties hereto agree that the best interests and welfare of the child would best be served with a cusotdy arrangement as foil ows: A, Tammy Lynn Steinbeiser and Cynthia D. Nale shall share legal custody of the child, B, Cynthia D. Na1e shall exercise sole temporary physical custody of the child. C, Cynthia D. Nale shall be responsible forsecuring medical insurance for t.he child. D, Cynthia D. Nale shall be responsible for providing all necessities for t.he chi ld. 5. All parties have had the opportunity to consult an attorney prior to execut.ing this agreement. 6. All parties hereto shall hereafter execute all instruments necessary to carry out the terms of thi s agreement. I CVNTHIA D. NALE, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSVLVANIA ; NO. q2- 310.3 : CIVIL ACTION - CUSTODY T AMMV L VNEE STE I NBE I SER, Defendant PETITION AND NOW COMES Plaintiff, Cynthia D. Nale, through her attorney, The Law Offices of Darrell C. Dethlefs, and avers in support of this Petition as follows: 1. Plaintiff, Cynthia D. Nale, an adult individual currently residing at 63 Arnold Road, Enola, Pennsylvania. 2. Defendant, Tammy Lynn Steinbeiser, an adult individual currently residing at 63 Arnold Road, Enola, Pennsylvania. 3. Both Plaintiff and Defendant, in an effort to ensure that the best interests of the child are met, have agreed upon the terms and conditions of the Stipulation Agreement as to Custody and Visitation, the original of which is attached hereto as Exhibit "A". WHEREFORE, Plaintiff requests to have the aforementioned Agreement as to Custody incorporl:lted into an Order enforceabl e by the Court. Date: By: Mi chael J. Pykosh, Esquire Attorney I.D. 56651 P.O. Box 366 3605 Market Street Camp Hill, Pa 17001 (717)975-9446 Attorney for the Plaintiff ! -, Stioulat1on A9reement as to Custody & VisHat10n On this ~~ day of May 199B, Tammy Lynn Steinbeiser of 83 Arnold Road, Enola, Pennsylvania, hereinafter "Mother", and Cynthia D. Nale of 83 Arnold Road, Enola, Pennsylvania, hereby agree to the following terms and conditions of custody and visitation of Elaine Diane Marie Steinbeiser, born April 24, 1998, hereinafter referred to as "Child". The parties hereto recite, declare and agree as follows: 1. Tammy Lynn Steinbeiser is the natural mother of Elaine Diane Marie Steinbei ser born Apri I 24, 1998. 2. Tammy Lynn Steinbeiser is on active duty with the Unit.ed St.at.es Navy, 3, Cynthi a D. Nal e is the foster mother and guardi an of Tammy Lynn Steinbeiser. 4. The parties hereto agree that the best interests and welfare of the child would best be served with a cusotdy arrangement as fall ows: A. Tammy Lynn Steinbeiser and cynthia D. NaJe shall share legal cllst.ody of t.he child. B. Cynthia D. Na1e shall exercise sole temporary physical custody of the child, C. Cynthia D. Nale shall be responsible for securing medical insllrance for t.he child. D. cynthia D, Nale shall be responsible for providing all necessities for t.he child. 5. All parties have had the opportunity to consult an attorney prior to executing this agreement. 6. All parties hereto shall hereafter execute all instruments necessary to carry out the terms of thi s agreement. I ..~"'" i 1/ J t:- Lt.,.: I.... . It; I ,~ I !:l) ~.. l ~ II'" "t! ;\ ~ \ , , , :;. I , . "- { [\_1 ,. in " t 1/ ,j , , I:, p;-'J. I' 1\ , ' it, t\-. , . CVNTH I A D. NALE, Plaintiff g JUN 221998 : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSVLVANIA '. v. : NO. TAMMY LVNN STEINBEISER, Defendant : CIVIL ACTION - CUSTODY ORI2ER. On this day of , 199B. It is hereby ordered that the Court of Common Pleas of Cumberland County adopt the terms and conditions of the STIPULATION AGREEMENT AS TO CUSTODY AND VISITATION dated May 29, 1998, with respect to the above captioned matter. J. !if .0 ;;:, I 511oula11on Agreement as to Custodu & VisHation On this ~c\"" day of May 199B, Tammy Lynn Steinbeiser of B3 Arnold Road, Enole, Pennsylvania, hereinafter "Mother", and Cynthia D. Nale of 83 Arnold Road, Enola, Pennsylvania, hereby agree to the following terms and conditions of custody and visitation of Elaine Diane Marie Steinbeiser, born April 24, 1 99B, hereinafter referred to as "Chil d". The parties hereto recite, declare and agree as follows: I. Tammy Lynn Steinbeiser is the natural mother of Elaine Diane Marie Steinbeiser born April 24, 199B. 2. Tammy Lynn Steinbeiser is on active duty with the United St.at.es Navy. 3. Cynthia D. Nale is the foster mother and guardian of Tammy Lynn Steinbeiser, 4. The parti es heret 0 agree that the best interests and welfare of the child would best be served with a cusotdy arrangement as follows: A. Tammy Lynn Steinbeiser and Cynthia D. Nale shall share legal custody of the child, B. cynthia D. Nale shall exercise sole temporary physical custody of the child. C, Cynthia D. Nale shall be responsible for securing medical insurance for t.he child. D. Cynthia D. Nale shall be responsible for providing all necessities for the child. 5. All parties have had the opportunity to consult an attorney prior to executing t.his agreement. 6. All parties hereto shall hereafter execute all instruments necessary to carry out the terms of thi s agreement. ! . ":-:'.. 7. All parites hereto agree that this agreement may be recorded and incorporated into an Order enforceable by the Court upon request of either party, WHEREFORE, this agreement shall be binding on the parties and their respective heirs, executors, administrators and assigns. WITNESS: WITNESS: SEAL) 4 ()l_'- .' a/f//! ~ ~A,(lp_ (SEAL) Cynthi a D. Nal e Date: .7/ '-7):/;'// /99 P I . , CVNTHIA D, NALE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSVLVANIA v. : NO. 98-3403 TAMMV LVNN STEINBEISER and CHAD L. DICKEV, Defendants : CIVIL ACTION - CUSTODY fEl IIJ.Wj AND NOW COMES Plaintiff, Cynthia D, Nale, through her attorney, The Law Offices of Darrell C. Dethlefs, and avers in support of this Petition as follows: 1. Plaintiff, Cynthia D. Nale is an adult individual currently residing at 83 Arnold Road, Enola, Pennsylvania. 2. Defendant, Tammy Lynn Steinbeiser is an adult individual currently residing at 83 Arnold Road, Enola, Pennsylvania. 3. Defendant is Chad L. Dickey is an adult individual currentl y residing at 130 Brandon Road, Butler, Pennsylvania. 4. A previous stipulation agreement as to custody and visitation has been filed on June 18, 1998. Said stipulation was not signed by Chad L. Dickey, the natural father, 5. Both Plaintiff and Defendants, in an effort to ensure that the best interests of the child are met, have agreed upon the terms and conditions of the amended Stipulation Agreement as to Custody and Visitation, the original of which is attached hereto as Exhibit "A". WHEREFORE, Plaintiff requests to have the aforementioned Agreement as to Custody incorporated into an Order enforceab by the Court./ Date: /.p/~q I q ~ By: Michael J, Pyko ,Es Attorney I,D. 58851 P.O. Box 368 3805 Market Street Camp Hill, Pa 17001 (717)975-9446 Attorney for the Plaintiff 1'. StiDulotion Agreement os to Custody 3. VisHotion 1'\ On this c2~ day of June 1 99B, Tammy Lynn Steinbeiser of B3 Arnold Rood, Enola, Pennsylvanio, hereinafter "Mother", ond Chad L. Dickey of 130'Brandon Road, Butler, pennsyl vani a, hereinafter "Father", and Cynthia D. Nale of B3 Arnold Road, Enola, Pennsylvania, hereby agree to the following terms and conditions of custody and visitation of Elaine Diane Marie Steinbeiser, born April 24, 199B, hereinafter referred to as "Child". The parties hereto recite, declare and agree as follows: 1. Tammy Lynn Steinbeiser is an adult individual and is the natural mother of Elaine Diane Marie Steinbeiser born April 24, 199B. 2. Chad L. Dickey is an adult individual and is the natural father of Elaine Diane Marie Steinbeiser born April 24, 199B. 3. Tammy Lynn Steinbeiser is on active duty with the United States Navy. 4. Cynthia D. Nale is the foster mother and guardian of Tammy Lynn Steinbeiser, 5. The child currently resides with cynthia Nale in Eno1a, Pennsylvani a. 6. The parti es heret 0 agree that the best interests and welfare of the child would best be served with a cusotdy arrangement as follows: A. Tammy Lynn Steinbeiser, Chad Dickey and Cynthia D. Nale shall share legal custody of the child. B. Cynthia D. Nale shall exercise primary physical custody of the chi I d. C. Cynthia D. Nale shall be responsible for securing medical insurance for the child. D. Cynthia D. Nale shall be responsible for providing all necessities for the child.