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Home My WebLink About98-06493 . "'J , . - .... ~ o Q - I~ I I ~ I - .... ~ ~ ~ I~ I - 10 (' .. ~ - . ~ '-.J 1'1). ~; >: -...! ! i . , 00; <:rj .j ~I i I su~h illness 1lI medi~al emergen~y. all panics shall h;l\c Ihc IIghl 10 visillhe child as oncn as he or she desires ~onsistcnl wilh Ihc propel' medical cafe of Ihe child ~ None of fhe parties shall do anything which nmy eSlflln!(e Ihe child from the olher 11<Irties or injure the opinion of the ~hild as to the other panics or which may hamper the Ii'ee and natural development of the child's love or atlcction for the other parties 6 Any modification or waiver of any of the provisions of this Agreemelll shall be enc~tive only if made in writing and only if executed with the same formality as this Stipulation and Agreement. 7, The parties desire that this Stipulation and Agreemenl be made an Order of Court by the Court of Common Pleas of Cumberland County, and thrther acknowledge thai the Court of Common Pleas of Cumberland County has jurisdiction over the issue of custody of the minor child, who has resided in Cumberland County since birth and shall retain such jurisdiction should circumstances change and either party desires or requires modification of said Order. 8, The parties agree that in making this Agreemelll, there has been no fraud, concealment, overreaching, coercion, 01' other unfair dealing on the part of the other 9, The panics acknowledge that they have read and understand the provisions of this Agreement. Each party acknowledges that the Agreement is fair and equitable and that it is not the result of any duress or undue inlluence, IN WITNESS WIIERI'O!-. Ihe pMlIes hereto inlendlllg to he le!(ally bound h)' the IClms hereol: set forth Iheir h,lllds and seals Ihe day ,Illd year herein mentioned i ' }' ~f (,', <.." It:LU-L_~'k,jh!:l,-,~._~.I/'/O'X~__~Q..-N..::''!:-.0, C JC'V\. / DATE IHENI~ O'DONNELL ~ ", Y:.{1 xC II. $/,,1 /i/\\ {- \\-\{') ((1\ DATE WITNESSES: ~' '" ~ N ~ 'J-., -}- ~ ~ \, .:s ' .. ~ ~~ ~~~ "( .. 'v~ ) , ~ ~ ,\.1 .' '~ ---: ~ "- .~ , ~ , rA, ,,(,' ~. \\J '"' Q I' ('. s;" \~ , V) I. \ ' \J '-A ~~ ~ , \~ ~, : 'oJ', " , ,.. '~ ., : .J,~ I ~' i' .::...:: ,. -.J" r:, " I"r ' , V" '('" '" 30 G 2- "v 1n'J~ ~~ u , ",'.iI . ',' ~ ~;# C~:./,'. .'I\"':~/\ ,': .J'" _ :-- N, ~~ C-\j '" , .... 1-( 1~} l' ~ '" ~ . 1 '~:{~ . c lJI NATIIAN!:. \l1l1.l',I'~~QI'IRE ATroRNE\'III NU, "7,00 "SOIrrIlIlANUVER STREET, SI'ITE 211I I:AIII.ISJ.E I'A 17111.1 (717) l-II-l~,\I. A'rrUIINH\' HlIllIlWENIIANT -_.~------~-------_.,,-,_._~.,._---------_.- .'"- -""---'''''''''''-'-- : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA IRENE A, O'DONNELL, Plaintiff v, : CIVIL ACTION - LAW TONYA A, O'DONNELL and, JOHN W. SIPE : NO, 1'J'J1l-6.j'J3 CIVIL TERM Defendant : IN CUSTODY STIPULA TION AND AGREEMENT THIS STIPULATION AND AGREEMENT emered imo this L dayoU.li, 2004, by and between Irene A. O'Donnell (hereinafter referred to as "Grandmother") and Tonya A, O'Donnell (hereinafter referred to as "Mother") and John W. Sipe (hereinafter referred to as "Father"). NOW THIS AGREEMENT WITNESSETH THAT: WHEREAS, the Father and Mother are the parents of one minor child, namely, SERENA MARIE SIPE (Age 5 years, born October 30, 1998); and, WHEREAS, the parties wish to emer imo an amended custody agreemem relative to the custody of the minor child, and, NOW, THEREFORE, in consideration of the mutual covenants, promises and agreements as hereinafter set forth and intending to be legally bound, the panies hereto agree as follows: 1. The parties shall retain shared legal custody of the child. 2, The Mother shall have prim.1lY phy.;ical custody of the child. \ 3. '/1le F.uher sh.11I enjoy periods of p.mi.11 ph>~ic.11 cusll.xly of the child froll1time to time as the p~nies nLlY ~gree. 4, '/11e Gr.mdmOlher sh.11I enjoy periods of f),\ni.11 ph)~ic,11 custody of the child from time to time ~s the p.ll1ies Imy ~gree. 5. The custodi~1 p~rent sh~1I ensure th~tthe non'custodi~1 parent has reason~ble access to the child by telephone. 6. TIle panies shall share custody of the child on holidays by mutual agreement, 7. '111e panics shall keep each other advised immediatdyrelative to any emergencies concerning the child and shall funher take any necessary steps to insure that the health, welfare and well being of the child are protected. 8, The panies shall do nothing that mayestmnge the child from either party or hinder the natural development of the child's love or affection for the other party, 9. Any modification or waiver of any of the provisions of this agreement shall be effective only if made in writing, \ , 10. The panies agree that in making this agreement there has been no fmud, concealment, overreaching, coercion or other unfair dealing on the pan of the other. 11. In the event of the breach of the agreement of the panies by any pany, the nonbreaching party shall have the right to file a petition for contempt of coUrt and to seek specific perfonnance of the tenns of the agreement of the panies, 12, The panies desire that this agreement be made an order of G:>un through the CoUrt of Common Pleas of Qrmberland G:>unty, and funher acknowledge that the CoUrt of Common Pleas of Qrmberland County has jurisdiction over the issue of custody of the panies' minor child and either party retains the right to file a petition for modification of custody with the CoUrt, but that this agreement shall govern until such time as the petition is filed and the matter can be heard by this Coun, ~ r, , IN WITNESS WHEREOr,lh,. p.mies hereto, imending 10 bc Icg.llly bound bylhe Icnns hereof, SCI fonh Ihcir h.mds and sc.lls till' d.lY .1I1d }1'.1r hcn'in sel fonh. WITNESSETH: L'~d7~( VfIl(j [. tJtFA/)V- vYY/.(J [ tJ~ ,~ c\.{J~SEAL) IRENE A. O'DONNELL '--::kn~Q OOntlf211J (SEAL) fg~A A. ~'D~LL / / (SEAL) ?NUPE , , COMMONWEAI.TH OF I'ENNSYLVANIA :ss: COUNTY OF CUMBERlAND On this, the ~I_ d.lY of ,\ \"~~L_, 2004, ht.forL', tht' under.;igned offitW, .tl'pt"m'd IRENE A, O'DONNELL knm\1lto me (or s,Uisf.KtOlily proven) to be the S.lIlle pel'ion whose name is subscribed 10 the within instrumelll, and acknowledged that he executed this agreemem for the purposes therein com.lined, IN WITNESS WHEREOF,I hereulllo set my h.lI1d and 0 'il:i.ll st'a!. "OT~RIALSEAL IlARlSAI. LE"MlcuilliA~~m'fll1Y CARUSLE BORO. R MY 1111 I ll'L'W( (,)",)cj /11." \; , ~ vv~....v\. (SEAL) Notmy Pub ic ,/ COMMONWEALTH OF PENNSYLVANIA :SS: COUNTY OF CUMBERLAND On this, the ti.. day of A,',~ 2004, before, the undersigned officer, appeared TONY A A. O'DONNELL, known \0 me (or satisfactorily proven) to be the same person whose name is subscribed to the within instrument, and acknowledged that she executed this agreement for the purposes therein contained, IN WITNESS WHEREOF, I hereunto set my ha ,'" d official seal. , , . ' COMMQ!!\"~'~T"'(," C.O"l"N~SYLVANIA ' /' r- ~o,",.-,...., il /./ ./ I . _'lat., ( .,'.'" "IJ:aryPubIic _ 'A--:C- , ' .,'IBL, ,"v, '",",ooI1lV1dCoooIy ctary Public/' L ~v,:o'''''''.~onE>pnoAp<,19,2008 /' f".,mber, f'enrllytvanla AuocIatlon 0' II .-; COMMONWEALTH OF PENNSY VANI : ,------- :SS: (SEAL) COUNTY OF CUMBERLAND On this, the 0-:1,1' day of ~t(1JT-; 2004, before, the undersigned officer, appeared JOHN W. SIPE known to me (or satisfactorily proven) to be the same person whose name is subscribed \0 the within instrument, and acknowledged that he executed this agreement for the purposes therein contained, IN WITNESS WHEREOF, I hereunto set my hand and official seal. ~ 0...-2 -- ;,<~. ~~lIbIii:-/ TH OF PEIJ:'J~YLVA I Notarial ;;';':1'" -. Nati1fr1c. Wolf, N,~;";': ,1L1I~iC . :",rllale 8010, Qmbtlli,if'l('! C'.~lI'rtv My Co",mla8Jon-'Apl i(i,~ MOmber, Plnii.y1vanla AuooI&tlon Of NOla".. c:COMM:'!\'!..~'" ~~ YlVANIA .I'I_~I ,'Jf.NolaryPt.Mc CW',' ''''-1ondI'_-, r~ . .........IIT ~':::" '" ,,,,. Apr,19, 200Il Momui.':. , ",.... \1SOCJ8110n Of Notari.. {' (SEAL) , ;~... :-,.~ i .;. ,~ '. , t ,~