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HomeMy WebLinkAbout00-05990 "...... .-- , " ~ " . AUG 31 zooriF MARY JANE THOMAS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. DO - S990 (?IU~( ,~ JOHANNA M. CRAVER, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this ,nif" day of ~ ' 2000, it is hereby ORDERED AND DECREED that the attached Custody Stipulation is made an Order of Court and said Custody Stipulation is adopted in its entirety and incorporated herein as an Order of Court. Dated: qf,( (J7) . .1 " II II I, II Ii I I; Ii I, ,I 'I' " Iii d JJ_ <," , ^" _n[rr,OC~ ,("",. ':" :CT!\RY GO SfP -., l Ii: 'lq t:,..... CU" "', "',. "'1Y : j~iio::.hLj i..rU'Ji~ I PENi~SYL\;)\NIA m~;[)!J~~r~~~~,"~~~l:~:~l!nl~~m':~I~!!f~I""l~ 1,1(,: ,ar , " I rTr~~. .. MARY JANE THOMAS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00 -59QO CUl{T~ JOHANNA M. CRAVER, Defendant : CIVIL ACTION - LAW : IN CUSTODY STIPULATION FOR AN AGREED ORDER OF CUSTODY AGREEMENT, made this ;;;; 2> ~ day of A '-'-"l \A:> 1- , 2000, by and between MARY JANE THOMAS, hereinafter referred to as "Maternal Aunt," and JOHANNA M. CRAVER, hereinafter referred to as "Mother." WITNESSETH WHEREAS, Defendant is the natural mother of one minor child, TANICA C. L. CRAVER, born January 5,1985; and WHEREAS, the child was born out of wedlock, the natural father has never been involved with the child's life and the whereabouts of the father are presently unknown; and WHEREAS, the parties have come to an agreement concerning the issues of child custody; and - , .' WHEREAS, the parties desire that this Stipulation be entered as an Order by the Court of Common Pleas of Cumberland County, Pennsylvania; NOW THEREFORE, intending to be legally bound, the parties hereby stipulate and agree as follows: LEGAL CUSTODY 1. Maternal Aunt shall have primary legal custody of the minor child, TANICA C. L. CRAVER, legal custody being defined as the legal right to make major decisions affecting the upbringing of the child, including but not limited to medical, religious, and educational decisions. 2. Mother has a right to be kept informed of the child's educational and medical development, and shall have a right of access to the child's educational and medical records. Mother shall be entitled to complete and full information concerning the child from the Maternal Aunt and from any doctor, dentist, teacher or similar authority, and to have copies of any reports, notices or other communications given to Maternal Aunt as the individual having custody of the minor child. 3. Maternal Aunt shall notify the other of any matter relating to the child, which could reasonably be expected to be of significant concern to the other party. 2 -"'~ .. 4. Day-to-day decisions shall be the responsibility of the Maternal Aunt, who has primary legal custody. PHYSICAL CUSTODY 5. Maternal Aunt shall have primary physical custody of the minor child, primary physical custody being defined as actual physical possession and control of the child. Mother shall have visitation rights with the child, visitation being defined as the right to visit with the minor child, but does not include the right to remove the child from the custodial person's home without the consent of the custodial person. 6. For the first year after the minor child's birth the Defendant had custody of the minor child. The parties believe that this custody arrangement was entered as an Order of Court; however, a thorough search of the records at the Prothonotary's Office did not yield evidence that a prior Order had been entered. 7. Beginning at the age of two years and up until July 27,2000 when the maternal grandmother suffered a stroke, the minor child lived primarily with the maternal grandmother, but she had frequent and continuous contact with the Defendant. 8. Due to the maternal grandmother's stroke, the maternal grandmother is presently unable to care for the minor child and the parties 3 ...; J ___ >> ~, ~ therefore seek to formally place custody of the minor child with the Maternal Aunt so that the child may be enrolled in school for the 2000-2001 school year, and so that the Maternal Aunt may provide health insurance and other benefits to the minor child. 9. Neither party shall impair the other party's right to physical custody or interfere with the other party's physical custody when the child is with that party. 10. Neither party shall disparage the other party in front of the child, whether the child is "sleeping" or "awake," nor shall either party attempt to alienate the affections of the child from the other party or allow third parties to attempt to alienate the affections of the child from the other party. WHEREFORE, the parties request that this Stipulation be entered as an Order of the Court. ~) f}Ne~ WI ess ~^Arl.h-- IA< ~ hanna M. Craver ~~ Witness m"'~~b Mary Jane as 4 ~,~~,~ '"~ ""~'i;]~l:~~ : '''--''~t'r' "'~i,J{..L",",'"",~ ,i., ~ ,.. .. . ' , ' :~, '_1] ~ ~"'~ .'!fil!i-. J' ~ o c., ~ 1~ ~ (j ~ iic\ ~ ~'rlr?~ ~~g~ f~ J o ~ tJ f~' n-1n, Z:;., 2:C--- C0 ..":::~ -< r <: ~C, -=-:-:C,' :PC: ~ -< , ~ o C) ". 2i Ct,) <':::1 co ~j .'" . i-, ~ . .1:1 ~- "'~ .. ~ """'c~ o .'.{, MARY JANE THOMAS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-5990 CIVIL TERM JOHANNA M. CRAVER, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this ~ 1#1.. day of ~ ' 2001, it is hereby ORDERED AND DECREED that the attached Stipulation for an Agreed Modification of Custody is made an Order of Court and said Stipulation is adopted in its entirety and incorporated herein as an Order of Court. Dated: i/~1 bl Judge JJoptW L1-J.I-OJ [I I, I I! II I: " I II !i Ii I, Ii Ii II II ,<, I; " Ii ,,- . . ""1-"'- ~'< '-~""~' - ,~, HU:D-O:~i:-I;~~E QF ';"l'H~I\:C)TARY 'OJ c:"'p 2' l I ".1:. _" otcl 8: '1-6, ," '. CUM[H:HLeJ'''JU COUNTY PENNSYLVANIA ~ MI!U I ~".",., ,lll_,","".,~".~~~,~"~~t~i':t_~~"'!1,*~!ii'J!!l~~ h' , ~ " MARY JANE THOMAS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-5990 CIVIL TERM JOHANNA M. CRAVER, Defendant : CIVIL ACTION - LAW : IN CUSTODY STIPULATION FORAN AGREED MODIFICATION OF CUSTODY AGREEMENT, made this day of ,2001, by and between MARY JANE THOMAS, hereinafter referred to as "Maternal Aunt," and JOHANNA M. CRAVER, hereinafter referred to as "Mother." WITNESSETH WHEREAS, Defendant is the natural mother of one minor child, TANICA C. L. CRAVER, born January 5,1985; and WHEREAS, the child was born out of wedlock, the natural father has never been involved with the child's life and the whereabouts of the father are presently unknown; and WHEREAS, an Order of Court was entered in this case by the Honorable Edward E. Guido on September 1, 2001 in which the Maternal Aunt was awarded primary physical custody of the minor child. The parties acknowledge and agree that Maternal Aunt will relinquish custody of the minor child to Mother, who is 1 "'" "'~ ,.'" ~ -r-' Q 1>$-' '. now in a position to care for the child or find suitable alternate custodial arrangements for the minor child; and WHEREAS, the parties desire that this Stipulation be entered as an Order by the Court of Common Pleas of Cumberland County, Pennsylvania; NOW THEREFORE, intending to be legally bound, the parties hereby stipulate and agree as follows: LEGAL CUSTODY 1. Mother shall have primary legal custody of the minor child, TANICA C. L. CRAVER, legal custody being defined as the legal right to make major decisions affecting the upbringing of the child, including but not limited to medical, religious, and educational decisions. 2. Maternal Aunt retains the right to be kept informed of the child's educational and medical development, and shall have a right of access to the child's educational and medical records. 3. Day-to-day decisions shall be the responsibility of Mother. PHYSICAL CUSTODY 4. Mother shall have primary physical custody of the minor child, primary physical custody being defined as actual physical possession and control 2 -, .~, '. ,'-'," ',' of the child. Maternal Aunt shall have visitation and partial custody rights with the child, said times to be mutually agreed upon by the parties. 6. For the first year after the minor child's birth the Defendant had custody of the minor child. The parties believe that this custody arrangement was entered as an Order of Court; however, a thorough search of the records at the Prothonotary's Office did not yield evidence that a prior Order had been entered. 7. Neither party shall impair the other party's right to physical custody or interfere with the other party's physical custody when the child is with that party. 8. Neither party shall disparage the other party in front of the child, whether the child is "sleeping" or "awake," nor shall either party attempt to alienate the affections of the child from the other party or allow third parties to attempt to alienate the affections of the child from the other party. WHEREFORE, the parties request that this Stipulation be entered as an Order of the Court. ~~..SG--=SL__ Witness ... -J ~ "A/\AII\ 1Y1, ('A 41' A.r-e..c Janna M. Craver A~ -('-.. liOC>T~ Witness ~ \'I\--;,.1\. . ......~~ Mary Jane T s 3 , ' ~.BilI!lllrr'~"l~~~~~,","""'.'~J"'il?1JM~W.$~~~g.~$&',':M-"€0-1.~~~.n-iJl~--' ., ....,. i ! I I i I I I ! [: . - , 0 0 0 C -T'\ 7' (/) :::-3 -~ -oU} M :-~:1J 92~ .0 ,I r'~ -,-~ r:~ :zc ~r.iC:) cliP: -.l =:c':) -<c''::::'- !;2CJ "'TJ is;! >0 ::E: ;':;;0 -.7.....7 :PC ~ Srn -? ~ ,,- ".- --' -< CO -< -,~ "