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Home My WebLink About00-05379 . . . . . .. Of. i1i",;t; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . . STATE OF Renee L. Freeburn Plaintiff . . VERSUS John W. Freeburn . Defendant . . AND NOW, DECREED THAT PENNA. No. 00-5379 DECREE IN DIVORCE .:r g:Jr-4."'. fYl~ I" ~()()I , , IT IS ORDERED AND Renee L. Freeburn , PLAINTIFF, AND John W. Freeburn , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None -- , -~ . By THE ATTEST: ~~~ PROTHONOTARY if. ;Ii"'''' . . . . < .' " J. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . In the Court of Common Pleas of Cumberland County, Pennsylvania Renee L. Freeburn, Plaintiff vs. Civil Action - Divorce and Custody John W. Freeburn No: 00-5379-Civil Defendant PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1, Ground for divorce: irretrievable breakdown under Section 3301 (d) of the Divorce Code. 2. Date and manner of service of complaint: August 7, 200, a copy of the Complaint in Divorce was mailed to the Defendant at 1809 Good Hope Road, Enola, Pennsylvania 17025, certified mail, return receipt requested, addressee only. On August 12,2000, that letter was returned to the sender "Refused". On August 12, 2000 a copy of the Complaint was sent to the Defendant at the same address U.S. First Class Mail. 3. Date of execution of the affidavit of consent required by Section 3301 (d) of the Divorce Code: April 4, 2001. Attached hereto as Exhibit "A". 4. Date of filing and service of plaintiff's affidavit upon the respondent: Filed: April 11 , 2001; Served on the Defendant April 13, 2001 by U.S, First Class Mail to 1809 Good Hope Road, Enola, PA 17025 together with a Counter-Affidavit and Waiver of Notice of Intention to Request Entry of Divorce Decree. 5. Although not required to do so, Defendant signed and returned the Counter Affidavit noting that he does not oppose the entry of a divorce decree and does not wish to make -any claims for econOinic relief. A copy is attached hereto as Exhibit "B". 6. Date Defendant's and Plaintiff's Waiver ofNQtice of Intention to Request Entry of Divorce Decree was filed with the Prothonotary: April 24, 200 I, Attached hereto as Exhibit "C-I" and "C-2". 'f!/:e A . AJ 1/1'1 La DM LL Ma en N. O'SulliVan, Esqurre AWimey foT the Plaintiff 324 Market Street- P.O. Box 502 Halifax, Pennsylvania 17032 (717) 896-3189 "' "r' " ,~, -"'r"l In the Court of Common Pleas of Cumberland County, Pennsylvania Renee L, Freeburn, Plaintiff vs. : Civil Action - Divorce and Custody Jowhn W, Freeburn No:00-S739-Civil Defendant NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter- affidavit within twenty (20) days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301Q>) OF THE DIVORCE CODE , 1. The parties to this action separated approximately four (4) years and have continued to live separate and apart for a period of at least two years. 2. The marriage of plaintiff and defendant is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. Cons. Stat. Ann. ~ 4904 relating to unsworn falsification to authorities. fir:' ~ :'OD! te g.,~~~~L-{. " Renee L. Freebnm !:-J ,-.-! !::: " ---~ -<: \D _, i\ i\ ,~ .. '. 1f In tire Court of Common Pleas of Cumberland County, Pennsylvania Renee L. Freeburn, : Plaintiff vs. Jowhn W. Freeburn Defendant Civil Action - Divorce and Custody No:OO-5739-Civil COUNTERAFFIDA VIT UNDER. 3301IDl OF THE DIVORCE CODE I. Check either (a)or (b): V (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (check (i),(ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): tI (a) I do not wish to make any claims for economic relief, ] understand thatl may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees, or expenses or other important rights. I understand that in addition to checking (b) above I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. I verify that the statements made in this counteraffidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. ~L ~hn W. Freeb Yo /'7-<1/ Date NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIMS FOR ECONOMIC RELmF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. ., \"\~ ~~, ,>" In the Court of Common Pleas of Cumberland County, Pennsylvania Renee L. Freeburn, Plaintiff vs. Civil Action - Divorce and Custody Jowhn W. Freeburn OO~S31<f No.BB S1J9.Civil Defendant WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER 63301 (C) AND 63301 ill) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses in do not claim them before a divorce is granted. .. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I veruy that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Date: 4r-; J If,, .;]()(!)/ ~:.~L ~ Renee L. Freeburn, laintiff (') 0 0 c ~;'j s:: :Po " "'OO~l -" mCT! ,;;:) , , "" 2::1.:' 1'0.) ,;""1 z~ "" c.) ~~.' .~ . "", >~ ~;:~ \<0 -u i";:C: ~o ..>. =-=.:;;.C) -0 ~ (jfll ;l>c .., Z -:11 ~~"'; ~ :.u (".) -< .' ,~ r - I ." ~ 1 In the Court of Common Pleas of Cumberland County, Pennsylvania Renee L, Freeburn, Plaintiff vs. Civil Action - Divorce and Custody Jowhn W. Freeburn : 00-$.1'19 No:99 5;::39 Civil Defendant WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER pJOl fO AND 63301 ID) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. : 3. I nnderstand that I will not be divorced nntil a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Date: y. /'1" -c1/ (') 0 C r .J "Os: "', . co :t>> 2~,F '"1:l ;:0 ., ,', :;;::~ N . 'I~~ (f;i" -.':-; rg ~:2~ -1'" :<::::c -Q ~:i_~") ~o ~ /~:i': :>0 ~(\ ~ ~ Of~~ ''-'1 j;} W .:..u -< II (' _ 7 1\ "-""''1" " !--,~ ~ ~> " ^-,-,. ~- ,,~ - n,'~ "~-~ () C) C z ..~,. -c.1t;:-; $J Inl~'-:\ Ee ~S; - %...:- ~c; -0 ~;>'~J -j... z<::) '-fl J:>C 2:;:; :2 -,~, -:.:.'! ,', ::.J __1.-"1"' ~~~; rr\ ::=4 .~ JlA~~~~'fIAA'~1J'lW"}"J;ffi'''''''''~''''-'Y;lj$;''''':'f1i)ffi;>''H-'I;1)~~t:llm!tJi!!lWl'''P1IfIl~i'<:''''''''''~ll" :-,-_~1\!1!1( In the Court of Common Pleas of Cumberland County, Pennsylvania Renee L. Freeburn, Plaintiff vs. Civil Action - Divorce and Custody John W. Freeburn Defendant No:60-537Q ~ NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court, If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court, A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the York County Courthouse, 28 E. Market Street, York, Pennsylvania 1740 I. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM, YOU SHOULD TAKE THIS PAPER TO YOUR LA WYERAT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET 'FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Legal Services, Inc. 8 Irvine Row Carlisle, P A 17013 (717) 243-9400 In the Court of Common Pleas of Cumberland County, Pennsylvania Renee L. Freeburn, Plaintiff vs. Civil Action - Divorce and Custody John W. Freeburn No: b-Q_sY79 (;wJ-r~ Defendant COMPLAINT UNDER SECTION 3301 (C) and ill) OF THE DIVORCE CODE 1. Plaintiff is Renee L. Freebum, who currently resides at 8004 Hatteras Lane, Springfield, Virginia 22151. 2. Defendant is John W. Freeburn, who currently resides at 1809 Good Hope Road, Enola, County of Cumberland, Co=onwealth of Pennsylvania, 3. Defendant has been a bona fide resident in the Co=onwealth for at least six months i=ediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 3, 1995 at Enola, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its Amendments. 7. The marriage is irretrievably broken and the parties have lived separate and apart for three and one half (3 Y, ) years. 8. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the court require the parties to participate in counseling. WHEREFORE, Plaintiff respectfully requests the Court to enter a Decree in Divorce divorcing Plaintiff and Defendant. COUNT I - CUSTODY 9, Plaintiff seeks joint legal custody and partial physical custody (with the partial physical ."" ,~ . ~ " ,,- , ~- ,. I ~-~ custody schedule to remain as stated in Paragraph 10) with the Defendant to have primary physical custody of the following minor child: Name Daniel Hill Freeburn Present Residence 1809 Good Hope Road, Enola, PA 17025. Age 8 years old (dob: 10-10-91) The child was born out of wedlock. 10. The child is presently in the custody of Defendant, with the Plaintiff having partial custody every other weekend during the school year, every other week during the summer vacation, and on alternating holidays and birthdays. 11, During the past five years, the child has resided with the following persons and at the following addresses: Name John W, Freeburn Address 1809 Good Hope Road Enola, P A 17024 Approx. Dates 1996 to present John W. Freeburn Renee 1. Freeburn 16A Springers Lane Birth - 1996 New Cumberland, P A 17070 12. The Mother of the child is Renee L. Freeburn, currently residing at 8004 Hatteras Lane, Springfield, Virginia. She is married. 13. The Father of the child is John W. Freeburn, currently residing at 1809 Good Hope Road, Enola, Pennsylvania. He is married. 14, The relationship of Plaintiff to the child is that of Mother. She resides with her two (2) children from a previous marriage, Christy and Mark Hutchison. 15. The relationship of Defendant to the child is that of Father. He resides with his son, Daniel Hill Freeburn, 16, Plaintiff has not participated as a party or a witness, or in any other capacity in other litigation concerning the custody ofthe child in this or any other Court, 17. Plaintiff has no information of a custody proceeding concerning the child pending in a court ofthis Co=onwealth. 18. Plaintiff does not know of a person not a party to the proceeding who has physical custody ofthe child or claims to have custody or visitation rights with respect to the child. f~ I ^ ..,. , . 19, The best interest and permanent welfare of the child will be served by granting the relief requested. 20. Each parent whose parental rights to the child have not been terminated have been named as parties to this action, WHEREFORE, Plaintiff requests the Court to grant her joint legal custody, and partial physical custody every other weekend during the school year and every other week during the summer vacation, and alternating holidays of the minor child, Daniel Hill Freeburn. And that each parent shall travel half the distance for both picking up and returning the child and that Defendant shall be required to seek Court approval before relocating more than 250 miles from the Plaintiff. Respectfully Submitted, ~~- Ma een N. O'Sclfi~, Esquire Attorney for the Plaintiff 324 Market Street - P.O. Box 502 Halifax, Pennsylvania 17032 (717) 896-3189 Supreme Court ID No: 81855 """".".., - . "- ~" ~". " . " , ^ In the Court of Common Pleas of Cumberland County, Pennsylvania Renee L, Freeburn, Plaintiff vs. Civil Action - Divorce and Custody John W, Freeburn No: Defendant I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. Ann. ~ 4904, relating to unsworn falsification to authorities. , .1 , ~!{,/jf./v Renee L. Freeburn Date: ~TJIy I~~ ,""7,~'" 'V '" '~,' " l!.\.J# ~, -~~.<~ ~. ., ;~, .."", " "~ !U, _ .~.. ..,~ 0 1t-~ ~t; ~o , ~-~. ~ "'~'""IT"~'.r' ~""-"-~'~'~-":',>"J~~''l{~rrrr1'N'~! _ '~';'<O'>"'("" '^,-~ iil~,'IiIiI'fQrnr"'" .su - -,...f (5 ~ ~ ~Y> CP. 'g~ g~ o J:.fj -Q~~H-3: \;:J [~ ~\ .)~ ~ - ~ " n C.~) :~) c: (::) :;;.,.,. 'I 9?:'~i~ "" ,C'~ . ':" , ......::- C--. . f\_., c:~ -"-, " " , , , -d , { .' -~;. B nl[JRJ!mMI'l'tftl' --=-,-. MlII"......".,~,,~~ . 'lHl!Il~!liiI<)j[!,;~. ,l!W(f,:m.~J!!;U".'~~iF%!'!I>~lWSil",,""1J'~"!'l!\f~ 1fI11't~I"k_""tJ. .. M~~__ "~ 1) In the Court of Common Pleas of Cumberland Connty, Pennsylvania Renee L. Freehurn, Plaintiff vs, Civil Action - Divorce and Custody Jowhn W. Freeburn 5:il-<:r No:OO 57J9=Civil Defendant NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter- affidavit within twenty (20) days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(D) OF THE DIVORCE CODE 1. The parties to this action separated approximately four (4) years and have continued to live separate and apart for a period of at least two years. 2. The marriage of plaintiff and defendant is irretrievably broken, 3. I understand that! may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa, Cons, Stat. Ann, ~ 4904 relating to unsworn falsification to authorities, &r:/ ~ :JODI te ~..~~~LL~ Renee L. Freeburn "'i-+"-"i , ~ ,. ~~" -~--~~ ~ a, !(~"""""1~_" ~ ~-,~ " _~<~. _ !!If_.~ ..'~ ~~ "~"--." ~ ,- ,",'-.' -,,-~"'''-:~ . . '" '" ',.",-^ -c- -'I,'""" ",'-~ "1,,'_ -"~, ^ -- o <;;;; .~}&:' m'fT ~f'- (7j :~: , , ~C:. )>C'. L~r-" .._,--- );-C 7' ~ -< C> :P" -~v ;::J ~,. r, -i", ~.D ~~: r.:- ~'__O ~ .,."" ~"",j~''lI1!'I!f! .." ~~M!ll'!3'I>!I~,J\'j~j::~~iJ!!I!P!m~~.",,,,,,~ ""':"~_"""',' In the Court of Common Pleas of Cumberland County, Pennsylvania Renee L. Freeburn, Plaintiff vs. Civil Action - Divorce and Custody Jowhn W. Freeburn 00- &'319 No:99 5739 Civil Defendant WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER 63301 (0 AND 63301 (D) OF THE DIVORCE CODE 1. I consent to the entry of a fmal decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verifY that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Date: fltr;) ~';;~(!)I ,e~.~L~ ~ Renee L. Freeb , laintiff tJ!q!m':~ I ~ <1' - ~ - -, -",~ ~ Ii II , 'i,ll' , " :!i :,:i '::1 1:1 iil !:!! I'::! ~' j: '11 ",j ~ 11 i'l iii :'!-1 ": , ~ - j :i "I ~. ~'- ~-,. <."~'-,^".- ~-' ~,-,--) -'" _;:m- '-"- ~"""." '" ""'-1 . , 2i c::' 0 -n 3:>0 ~j -0 rn :::0 M'l.Ii ~~' ~ ,. .t:"" :gtJ ~o Cr(~ -0 g-~ ~8 :l!: 5>c: f'S Zm OJ ~ Ul ~ c.J -< ,,"l!l!II~!I!J~_~IIi'P-~~'~~"'!!ff;.~I~~'f'~W:iw_,,.,*";m~~~~1 . ~-, -'. In the Court of Common Pleas of Cumberland County, Pennsylvania Renee L. Freeburn, Plaintiff vs. Civil Action - Divorce and Custody Jowhn W. Freeburn CX) -S37f No,88-5'l'J9-Civil Defendant WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER ~3301 (C) AND &3301 CD) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities, Date: Y-/tf-C!/ ~-~"-"lIr l.~ -, 'I' " - ~~ :\,,- 7 - - <", ,--',',",- "~.,,"' . " mm g 0 ~ - ; ~ .-It .~~ :j:_;H( ::::0 l,.......,.-~ "f- N ;Q~i ~'i X'" ~L) 6 .......- -<, -0 (~~ '<:: :x jg -'(;. ~ ~r'n ,,,,", ~, ~ ~ (.i:> -~,.="""~, - ~~!IfjI~~",~}~J'f'i~~~'~,"'W"\!j"W".'t1f~~lf-l'!11NI!~''rnl'W$1I!~~3ij!!''\1'~ljlJ'f-f.:j _ '~.<'.,", _ e." ./ ''/I ~ , . IIi the Court of Common Pleas of Cumberland County, Pennsylvania Renee L. Freeburn, Plaintiff vs. Civil Action - Divorce and Custody John W. Freeburn 3+~ No: OO~CiVil Defendant AFFIDAVIT OF SERVICE Maureen N 0 'Sullivan, Esquire, being duly sworn according to law, deposes and says that she mailed a copy of the Complaint in Divorce filed in this matter by certified mail, return receipt requested, addressee only, to the Defendant at 1809 Good Hope Road, Enola, Pennsylvania 17025, on August 7, 2000. On August 12, 2000, that letter was returned to the undersigned marked "Refused". A copy of said envelope is attached hereto as Exhibit "A." On August 12,2000 a copy of the Complaint was sent to the Defendant at 1809 Good Hope Road, Enola, Pennsylvania 17025, D.S, First Class Mail. That letter has not been returned to the undersigned. Sworn to and subscribed before me this fJp day of ..-:x,r~~' 2000. NOTARIAL SEAL JI/IlI1H THOMPSON..Hotor, ..... __ /..0......_ e..nty Mr Com~ EopIres NOV. '8, 2GOO ! ~, . , ~~ ~'ifF ! , " fi ~ <;> ~;.T (5 :;} w '" cr; M t; rt g Ln~ aoxN- I- a-,tR a.._a:.r:?.....Z "' <ru.......,-:;:) .If) v>a.......~C~ l..C1r-- ::i $ g<J: -ER-g _ cr; '" "' N '" " ! \ \ ' J ~ \ * ~ \ I i ~ :' ~._!'S' r;;.. 'f~ ~ f ~r- tf" (-". j , '" '" o '" \ \ \ \ N o V) ~ CO ~ O~ ~ o..:~ - " ;::l _N '" <l.lM o~E~ .....l"'- Z"lilv< ,:; ......;:: 0.. Q) Cl) CO f\ ~g~~ Cd ""1"...... ~EiN<<l "'M::I:: "-~""""'- -"".....'i\:'l" ,~ /0< ,5'/\ ~~ . -.,,~ ~- ." 'c::1 -~ ~ ~ ~\ 'f-, "" V:';' (,. #'l Ii: ii::c::t :S~ CI: CoO .~ =1:> s>>l -,. , , ~ ~ ~~ ,~ ',_,,';",' .r. '-I ~""''',' tll: " ,<- ,._IIlT _~, . ,""".,.~ ---~~~'- .~ ."~ " " " , , () 0 0 C 0 'T' s: W r..1 ~W ,..., ;~ :JJ "tl "r :::JJ 'Rtn ZS;: 0:> :09 (/)' 0' ~L -",9 ~o -0 ...,.~. I' "'_.~ ~o :x OB 2m ;t>g - ~ .. ~ Ut ~ (:) ~, ~~,..~i!!ffi'~Fl"l"~"'~~''''!''"I~I;;J't'RN~~~I!l''r.'?('~~""""", __,,",~._, / i In the Court of Common Pleas of Cumberland County, Pennsylvauia Renee L. Freeburn, Plaintiff John W. Freeburn Civil Action - Divorce and Custody S;)lq No: OO-S139-Civil vs. Defendant AND NOW this J. 'a-..J... ORDER day of ~ , 200 I, the parties having reached an Agreement regarding the best interests of the subject minor child, Daniel Hill Freeburn by entering into the attached Custody Stipulation, it is hereby ORDERED and DECREED that the attached Custody Stipulation is entered as an Order of this Court. J. , "- p lGt Q?(y ~ ;,-~ ~""""'" ~---- I II - ~~""~"' "",,-,., " .-',- '>- b:: ..-::( y: ~~~ (1:,~~,:~ tD!..J. ~.::::! ~...- - ') o 1Jj N 2:: '2 :::J~ C)~ rJZ '. ~ ,,::.:::i ~7>- :~{'U) ..::lZ a:Z '-_Ut.!J [Do.. Z :::J o :2 "T: ~ C".J ('-J c:: ...:.:1: .,,- - c:> O~, ~ .,. ~i: J~ A1RL. . I~ ~ " '" .' -o<~ . -~ ,,"',C" ,,-, -"."'P '_>'"", " \ _. _"""~_~ ,_ ~,__ _ '.f~~@;"t~W_,"_i'~~~~f~rom'~_~__~,~.-.-.~.~~~~l!!i1," ".' " In the Court of Common Pleas of Cumberland County, Pennsylvania Renee L. Freeburn, Plaintiff vs. Civil Action - Divorce and Custody John W. Freeburn No: 00-5739-Civil Defendant Custody Stipulation AND NOW this / day of 7'1~ , 200lf', the parties have reached an agreement with regard to the best interests of the subject minor child, Daniel Hill Freeburn: I. Plaintiff, Renee Freeburn, hereinafter "Mother" and Defendant, John W. Freeburn, hereinafter "Father", shall have shared legal custody of the minor child. Father shall provide Mother with a copy of the schedule for all school related and extracurricular activities for the minor child, 2, Mother and Father shall have shared physical custody of the minor child with Father to have primary physical custody. 3. Mother shall have partial physical custody of the minor child every other weekend during the school year commencing on Friday afternoon until Sunday evening and every other week during surmner vacation, unless otherwise agreed upon by the parties. 4. Mother and Father shall share physical custody of the minor child for all holidays and the minor child's birthday by alternating custody each holiday every other year. In addition, Mother is to have one week of partial physical custody of the minor child over the Christmas/New Year vacation from schooL. 5. Mother and Father agree to share eqUlllly in the transportlltion of the minor child for the periods of partial physical custody with the Mother. 6. Mother and Father agree that, should either party relocate to a distance that would make them more than 200 miles apart, this custody matter would have to be modified accordingly in the best interests of the minor child. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the date and year first above written to the aforesaid Custody Stipulation. Witness Witness ~~~~ ee Free urn, am iff '::i.J! ~, .~.~ t"f j';i ~ _ ,I..,., ", '" , - ~. .~ ,f ,\. 0 0 0 C ,'1 ~. 3', _.,,~ -oeD JY -;h;:l 101m :;;0 2:X' i'1 7-C,- -.;~:'~' mK 0 iZ!~~I, ,<.,,- G:CJ :::~ ~~~ ?~ ~o -,. -0 '2 J:>c ~,-l Z 0 ;p :<: .':J (f\ -< 7" n'" e,,~ ~~, TV"'lfJ] '" '.1>'~';"'~''''''_'''''F:!tIIIl,.,~,. . ~", ~~~[gl_'~'''!r,'''i4'_~il!!'i;\il~lWm~~!I!i!niH._~_~.,._, 4l :", ,~~ " f , . - ~ In the Court of Common Pleas of Cumberland County, Pennsylvania Renee L. Freeburn, Plaintiff vs, Civil Action - Divorce and Custody John W. Freeburn No: 00-5379-Civil Defendant ~ER!'!~!CATEOFSERVI~E Maureen N. O'Sullivan, Esquire, hereby certifies that she is the Attorney for Renee L. Freeburn, Plaintiff in the above-captioned matter, and that she did, on the 13th day of April 2001, forward to Defendant, John W. Freeburn by U.S, First Class Mail at 1809 Good Hope Road, Enola, P A 17025, a file stamped copy of Plaintiff's Affidavit under 3301(d) together with a blank Counter-Affidavit and Waiver of Notice of Intention to request Entry of Divorce Decree. r ~ " c ~1lI .. -'" ~lf,~P'!' ~ ,<"""=,,T., ""~ -~- ~ - "" ~.' , \, (} ~- .-0 r~,l. l~~~ ~t:) 'J?C bC) 'Pc:. ;Z. -J ~, o -- -::;:. -"~1' ':::,c, ~ - .. ~'" " -:~1 ',-;\ , ._4 -v. ,.'~\ :-t, -1"1 ~:i)~~:, -~~. :i1~ ..,l" (t! ...., - .-" _.c~.,.,...~- .'..r_~,!W'!'~,*I'l~J";'jlr}~I;lW"~'~~~~~!l~~ "'. =.~__ " H~ /k&~ /I~ atl!aw. 324,11ct41ud $twd"" p('). &n. 502 dI+. ~ 17032-0502 1131: (717) 896-3/89 ~: (717) 896-296/ May 10, 2001 Prothonotary of C\Jmberland County I Courthouse Square Carlisle, PA 170B RE: Renee L. Freeburn and John W. Freeburn Divorce and Related Matters No: 5379-00-Civil Dear Prothonotary: Enclosed please fInd Vital Statistics Form and two (2) proposed Divorce Decrees for fIling with your office. Also, please be advised that the social security numbers for the parties are as follows: Renee L. Freeburn John W. Freeburn 177-42-4888 303-66-2148 Also enclosed is a self addressed stamped envelope for return of a certifIed Divorce Decree. I had previously provided you with a stamped envelope so that a Decree may be forwarded directly to John Freeburn. If you have any questions, do not hesitate to contact me. Very t Y yours, . LflO~ Maureen N. O'Sullivan Enclosures '1',r ,"'- -c:" ~:--'''"''- ,",,-' . r _ ,n