HomeMy WebLinkAbout98-06685
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MARY JANE KANTZ.
I'lalntilr
('OIJltT OF COMMON I'LEAS OF
('l1~lIlERI.AND ('OUNTY-I'ENNSYL VANIA
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CIVIl. TER~I
MELISSA CONRAD and
SCOTT RAUDAUAUGII
Dcfcnd,lIlt
('IVII. ACTION-CUSTODY
ILL -).f - (, (. ; ~ (" (~ (
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OImER OF COURT
AND NOW, this I~lrday of \..-~" 1998 upon presentation and
consideration of the within Custody Stipulation and Agrecment it is hcreby ORDERED
and DIRECTED that the aforcmentioncd Stipulation and Agreement is made an Order of
Coun and all prior ordcrs in this case relative 10 custody are hereby vacated,
cc: Bradley L. Grimc, Esquire
Attorney for I'laintill'
Melissa Conrad. pro sc
Scott Raudabaugh, pro se
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MAR Y JANE KANTZ,
I'laintilT
COURT OF COMMON I'LEAS OF
CUMBERLAND COUNTY -I'ENNSYL VANIA
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CIVIL TERM 1/, 'II. (,f;[",('",c( T",_
MELISSA CONRAD and
SCOTT RAUDABAUGH
Defendant
CIVIL ACTION.CUSTODY
CUSTODY STIPULATION AND AGREEMENT
THIS STlI'ULA TlON AND AGREEMENT entered into the day and year
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hereinafter wriUen by and between MARY JANE KANTZ (hereinafter referred 10 as
WHEREAS, Mother and Father arc the nalural parents of the child Kayla Marie
"Grandmother") and MELISSA CONRAD (hereinafter referred to as "Mother"), and
SCOTT RAUDABAUGH (hereinatler referred to as "Father"),
Conrad, born July 7, 1995 (hereinafter referred to as "Child");
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WHEREAS, Grandmother is the natural maternal grandmother of the child;
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WHEREAS, Mother and Father presently live separate and apart and neither
parent resides with Grandmother; and
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WHEREAS, the parties wish to enter into a comprehensive agreement
establishing an arrangements relative to custody, temporary, and visitation of the child,
NOW, THEREFORE, in consideration of the mutual covenants, promises and
agreements as hereinafter sel forth the parties stipulate and agree as follows:
J, Grandmother shall have primary and physical and legal custody of the
child,
2, Mother and Father shall have periods of temporary or partial physical
custody with the child or periods of visitation, by mutual agreement
betwccn them, individually, and the Grandmother II is not intended
that these periods of' temporary physical custody or visitation be
exercised juilllly but rather thai mother and father shall have
indep.nd.ul perillds of time with the child In implementation of'this
paragraph, it is intended that the periods of'temporary and physical
custody or visitation as described herein shall be exercised in a
reasonable and liberal manner,
3, MOlher or Father, respectively, shall be responsible for
Iransportation for the child lor their periods of visitation or temporary
physical custody,
4,
All panics shall keep the others advised immediately relative to any
medical emergencies concerning the child and shall, funher, take any
necessary steps to insure that the health and well being of the child is
protected during suck! illness or medical emergencies, All panies
shall have the right to visit the child as often as he or she desires
consistent with proper medical care of the child,
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5,
None of the panics shall do anything which may estrange the child
from the other panics, or injure the opinion of the child as to the
other panics, or which may hamper the free and natural development
of the child's love and alTection for the other panies,
6,
The panics desire that the within stipulation and agreement made an
Order of the Coun in the Coun of Common Pleas of Cumberland
County and funher acknowledge that the Coun of Common Pleas of
Cumberland County does, in fact, have jurisdiction over the issue of
custody of the child in that the child has resided for her entire life in
Cumberland County, Pennsylvania, Court of Common Pleas shall
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