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Home My WebLink About98-06769 , JI '7 ~ "r (.. l.J.. f t- o V .r j 0- .3 r- ..j I ()O CY . . .--' ~. l. 1'1" II II If I IN '1'111': COUIl'I' OF COMMON PL.EAS (,IJMI\I':I<LANI> COUN'I'Y, PENNSYLVANIA Ill), {iJ' L./I.'! (it'{C'tC_ ('IVIL ACTION- LAW IN CUSTODY '~ I". ! i<Y I" , :-:,. I,: '{ ; ~ 1-, 'I If J'! ~ 't I'; I Ii(" ('/HI,,"I MIl) NO'!I, l.hi S QRDER OF COURT ~~ ddY of '\ )Jk~.......... - , 1998, i:l "'."""idcl,,Liun 01 l.Iw dt.t,dched Stipulation, voluntarily entered ;',i" 1>1' l.1>" ldfLics, iI: is herehy ORDlmED AND Df,CREED as follows: I, 'l'he pal-ties shall have shared legal custody of the ":'''',: ",ii'O! chi ldren, They shall consult with each other i,dIV(' I() all important decisions concerning the subject minor ":I: :d,e:n, incllldin'J such matters as health, education, and '-:.o.1.1<j';on. 2. The parties shall have shared physical custody of '," ~"uhject minor chi ldren, pursuant to the following schedule: ^. During the school year, Mother shall be entitled to custody from 6:30 a.m. until 2:00p.m, Mother shall be entitled to go to Father's house at 6:30 a,m, and help 'Jet the children ready for school and on the school bus by 7:10 a,m. The children shall pick up the school bus at Father's house every morning, with the exception of Monday morning following Mother's custodial weekend, as set forth in paragraoh 2(c), B, Durin'J the school year, Father shall be entitled to custody of the children Monday through Friday, (rom 2:00 p,m. until 6:30 a,m, the [ollmling day. It is acknowledged that he will be present in his house when Mother comes over to help get the children ready for school and on the bus at 7: lOa. rn , f-'~ ,'. PI" 1111) till' :;('h"" I y"dr, Molher shill I be l'1l1 Illf.d lo ('v(~t y (JUI\~r wL'(~kond, c;omflH~ncjnCJ :...IIl\oi..y.1l 'I:(J(J ",111, unlil Monday ill. 2:00 p,m, 111>1111'1 :;I,.i1II"'I!'''!>')!l"ibl., forillltlilnsportiJl.lon IIH'ludillq bill TlfJI ]illlitt!d lo lral1~porLin<J tho 1'lIi Idl "11 10 sehool on Monoay morninq fol lowing Iwr ('list od i d I \tJ{~l~k(~JH1. 1;, DUlill'! the children's summer vacation, Mother ,,11..11 II" entitled to custody of the children MOllddY IllnJllqh Friday, lrom 6:30 a,m, until 2:00 !>,III, Mother shall !>["(lVide transportation relative I u h,,'r (ledods of custody, Mother shall pick up ,md drop off the children at Father's house, E. Durin,) the chi ldren' s summer vacation, Mother sllall be entitled to every other weekend, cOlllnwncinCj Saturday at 9:00 a,m, until Monday at 2:00 p,m. Mother shall provide transportation to and from Father's house in order to effect the ~cekend schedule. 1', During the children's summer vacation, Father shall be entitled to custody Monday through Friday from 2:00 p,m, until 6:30 a,m, the following day and alternating weekends, G, During the children's summer vacation, both parties shall be entitled to two consecutive or non-consecutive weeks of uninterrupted custody upon 30 days written notice to the other party, fi ! H. Commencing with Thanksgiving, 1998, the parties shall alternate the holidays of Thanksgiving, Easter, Memorial Day, Independence Day and Labor Day, with the exact details to be agreed upon between them, Father shall have Thanksgiving in 1998. f"' I, Christmas shall be divided into two segments, Segment ^ shall be from December 24th at 12:00 noon until December 25th at 12:00 noon. Segment B shall be from December 25th at 12:00 noon until December 26th at 12:00 noon. In even numbered years, Father shall have Segment A and Mother shall have Segment B. In odd numbered years, Mother shall have Segment A and Father shall have Segment B. J, 1~e parties shall share the children's , SCOT'r E, I'I<Y~;, , .. , Plainl.i II IN '1'111,; COUHT 01' COMMON PLEAS CUMIlEHLANIJ COUNTY, PENNSYLVANIA NO, 'r,. (....IV ( v, MARY BETII FRYE, Defendant CIVIL ACTION IN CUSTODY LAW MOTION FOR ENTRY OF CUSTODY ORDER AND NOW comes the Movant, Scot t E, .'rye, by and through his attorney, the Law Offices of Silliker and Reinhold, and respectfully presents this Motion for Entry of a Custody Order as follows: 1, Movant is Scott E, Frye, an adult individual 1 I currently residing at 24 South Second Street, Wormleysburg, Cumberland County, Pennsylvania. i I'; I} II [i i~ i\ 2. Movant Scott E, Frye and Defendant Mary Beth Frye are the natural parents of four subject minor children, Brandon Scott Frye, born July 24, 1987, Ethan William Frye, born March 7, 1989, Morgan Sydney Frye, born March 15, 1990, and Colin Robert Frye, born March 12, 1991, 3, The parties entered into negotiations regarding a custody arrangement which would be in the best interests of their subject minor children, and have reached an agreement which is set forth in the attached Stipulation for Child Custody, , '.1'" 4, The 1''' I lie,; b..1 i "V" I. h.. :; I i Pili" I j Oil for Ch i 1 d ClIslody is ill thell childll'll''; b..st Illtl''''SI.,;, WIIEI~EF()HE. Mov.lIll. :;('011 E, I'r ye. resp<,ct lu J I Y requests this Itonorable COlllt elller the p"rli(,s' Slipulalioll "s all Order of this Court. Date: l\j30jC/'J Attorney for Scott E. Frye :;I'()j i ,. i-j,'V!, 1'lolIIII, If I tl '1111: ('OlJH'J' OF COMMON "LEM; ('IJf~IWIII.Mm COlJNTY, I'ENN~iYLVAN J A 'J, IH>, i,!,',I,''! HI'l'/I Vh'YI- (' I V I L M:'1 J ON I N ClI~iTOIlY LAW /ll'j.-nddflt STlPU~ATION FOR CHILD C_~STODY Th(' pdri iI'S hl',..to, Scotl. 1';, I'r'y.. and Mary lleLh Frye, lbl 'If',,] p"'''IlL-; of the subjl'cL millor children, Brandon Scott ;":"', bUIll ,July 21, 19B7, El.han William I'r'yc, born March 7, 1989, :'"" '" ~;yd,,,,y I,',y", borll March 15, 1990, dnd Colin Hobert Frye, h',:: ;'~"cch 12, 1991, hereby volunta,'Uy agree and otherwise ,; ','ill;,:" t,o tile follm'/inq: I. The parties shall have shared legal custody of the 'it,~) ;'!l:l. minor children, They shall consult with each other r, 1,,'Li'/e to all important decisions concerning the subject minor C", ,,j'c0n, including such matters as health, education, and t:'T~.i.CJ~()n. 2. 1~e parties shall have shared physical custody of U:," subject minor children, pursuant to the following schedule: A. During the school year, Mother shall be entitled to custody from 6:30 a,m, until 2:00 p.m. Mother shall be entitled to go to Father's house at 6:30 a.m, and help get the children ready for school and on the school bus by 7:10 a,m, The children shall pick up the school bus at Father's house every morning, with the exception of Monday morning following Mother's custodial weekend, as set forth in paragraph 2(c), \ 1\, P,li j IIC) II,P schoo I y"d r, I'a t hel' sha J 1 ho "111 II I,'d to custody of the chi Idrell Monday throuqh 1'lIddY, 1101112:00 p,m, ulltil (.:JO a,m, the Il>lltH'''''! cJdY, It is .",knowledl/I!d thal ho will bo p"',,,'nl III his hous(! when Mothel comes over to 1;"1 pIl"I II.., eh i luren ,,'ady tor school and on the I..,,; at 7: lOa ,111, C, Illlrilll} the school yeilr, Molhor shall be "IILi I Jed to every other weekend, commencing ~;.dlllddY at c):()0 a,m, until Monday at 2:00 p,m. Mo!.h,,,' sha.l I be respons ible [or all transportation illcluding but not limited to transporting the children to school on Monday morning following her CII,; tod i a I ~Ieekend, II, During the children's summer vacation, Mother shall be entitled to custody o[ the children Monday through Friday, from 6:30 a.m, until 2:00 p,m, Mother shall provide transportation relative to her periods of custody, Mother shall pick up anu drop off the children at Father's house. E, During the children's summer vacation, Mother shall he entitled to every other weekend, commencing Saturday at 9:00 a,m. until Monday at 2:00 p.m. Mother shall provide transportation to and from Father's house in order to effect the weekend schedule, F, During the children's summer vacation, Father shall be entitled to custody Monday through Friday from 2:00 p.m. until 6:30 a.m, the following day and alternating weekends. G. During the children's summer vacation, both parties shall be entitled to two consecutive or non-consecutive weeks of uninterrupted custody upon 30 days written notice to the other party. H. Commencing with Thanksgiving, 1998, the parties shall alternate the holidays of ThanksgiVing, Easter, Memorial Day, Independence Day and Labor Day, with the exact details to be agreed upon between them, Father shall have ThanksgiVing in 1998, I. Christmas shall be divided into two Segment A shall be from December 24th at noon until December 25th at 12:00 noon, segments. 12: 00 Segment B . r i; j ! f. 11' r :,1,..11 I", 1",," 1)('''<''1[11'''1 25111 ill 12:00 1I00n unlil P""'IIII><'I ;'(,111 ,J! 12:00 110011, III "ven numbered ','1'011 :;, "'dtlll'f .':hci II hdV(' ~;(l<Jm(~llt ^ and Mother :,11..11 II..v,' ~;"qll"'1l1 II. III odd lIulllblned yedrs, ~"<lllll'l ::11.111 ""vI' ;;"'lIll"lIt ^ i1nd I"alher shal I have :;I'q'llt'Jd H. .) , 'I'll" I'd 1 I ,,,S slid I I shd n, the ch i ldren' s l,jrlllddY'; wit.h 1I\(~ (~xdcl delails to be worked out hl'I\..,,(~ct' Lh~~III. \, !IUlill'l ,lilY p"riod of custody or visitation the (,..,ij... !<lItI'S ordpr Shd]] not possess or use any controlled .'!i;.::I,II"',., j\"It.lwr "IIal] they con~;ume alcoholic beverages to the !""1l1 ,;f jnlo:,:ical.ion, Tile parties shall likewise assure, to the ,':'I'n: po,;,;;b]e, thal other household me'Tlbers and/or house guests ">c,r,,,' ,..Iii II IIIi" prohibition. .~ Tile parties have pledged to communicate freely, '.:""P"'''' l.(' lu 11 y, and 'leneral] y work together in order to ensure i.;.,. bl'sl interests o( the subject millor children. ",' !fI0" /~)}/((ij .,{. {It;;" cr, >1 vii. tness tI / 'J',.I, / I ~ I L ' .... , ,_~' 11Jr 7 II j , I 'I'll Lness v.... /i'/ {.(/> ;/ . ,I ,~J;;f 'iI.4zt> ~d,,;Z;Z{ Mary B h