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Home My WebLink About00-06002 . ,~ ~'>< ~ '. ~'" ,", -" '. ,"-i <. . . . . . . . . . . . . . . . .. . :f. :Ii:f.:f. . . . . .. . . .. . ... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . . STATE OF PENNA. . . . ANN W. YOUNG, 00-6002 No. 2000 Plaintiff . . . . . . VERSUS . . . . JOSEPH A. YOUNG, Defendant . . . . DECREE IN DIVORCE . . . . . . . . . . . . . 1aJ( , IT IS ORDERED AND AND NOW, . . ANN w. YOUNG DECREED THAT , PLAINTIFF, . . . . . . . . . . . . . JOSEPH A. YOUNG AND , 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; . . . . }JOve- . . . . . . . . . t~ PROTHONOTARY . . . ... . . . . . . . . . . ';"1' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . r ,~~ ,"', ' -~., fl\div\ltrnsmit.pcp\7-9{ ... ANN W. YOUNG, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-6002 CIVIL TERM JOSEPH A. YOUNG, ACTION IN DIVORCE 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 ~ (3301(c)} ~ of the Divorce Code. (Strike out inapplicable section) . Acoept~ce D,*~]!c.warn~'d ~~p~erif,i'2'008f the complaint: Hand delivered Aug. 30, 2000, 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by ~ 3301(c} of the Divorce Code: by Plaintiff Nov. 28, 2001 ; by Defendant Nov. 28 2001 . - (b) (1) Date of execution of the affidavit required by ~ 3301(d) of the Divorce Code: (2) A. Date of filing of Plaintiff's affidavit upon respondent: B. Date of service of Plaintiff's affidavit upon respondent: 4. Related claims pending: NONE 5. Complete either (a) or (b): (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date Plaintiff's Waiver of Notice in ~ 3301(c) Divorce was filed with the Prothonotary: ;.J- /(0 II) i Date Defendant's Waiver of Notice in ~ 3301(c) Divorce was filed with the Prothonotary: /,)..!(d!OI 'Attorne Supreme Court No. 40486 .[m""; '~~IJlin' ~'''''~~b!ffi!!iili<i:m;~~Bi~*,jH~t'~~ltf:1~iiillh~~~~~l~,I.iIioliiiM:''" .. , iIiI!II.1IIJ " ~ " e z ~~~ ~~~ ~c:~~ zee, ~, Fe z ::;! .,,- ." r--', r::J ,"" n o ---,,~-j --0 ~:'.?;;,~:; '-r: ~~ \D '-""'-; ;=;:; 5J -< " ~ I, -. -.'- ,=- <",,: ""'-~;'-"".' ." <', ,>, ,~"" -;." ,--,', , ~~;j . ANN W. YOUNG, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. O()- (j{;6;) CIVIL TERM JAY A. YOUNG, Defendant CIVIL ACTION - LAW IN DIVORCE 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 Cumberland County Courthouse, Carlisle, PA 17013. 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 LAWYER AT 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. Cumberland Countv Bar Association 2 Libertv Avenue Carlisle. PA 17013 Telephone: (717) 249-3166 II Ii .::. d1i j "'om'J .-- ,"",>-,",y" 0"'- ';~ -, .:-;". .C--- ",,"'. "' ~' ,; 'm' '~~ fl\div\youn~\8~OO ~ ANN W. YOUNG, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. iJO-(,(JO.z, ~ Tu....... v. JAY A. YOUNG, Defendant CIVIL ACTION LAW IN DIVORCE COMPLAINT 1. The Plaintiff in this action is ANN W. YOUNG, an adult individual, who currently resides at 2815 Fairview Road, Camp Hill, Cumberland County, Pennsylvania, 17011. 2. The Defendant in this action is JAY A. YOUNG, an adult individual, who currently resides at 2815 Fairview Road, Camp Hill, Cumberland County, Pennsylvania, 17011. 3. Both the Plaintiff and the Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were lawfully joined in marriage on October 21, 1989, in Duncannon, Perry County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The Plaintiff avers as the grounds upon which this action is based is that the marriage between the parties hereto is irretrievably broken. -1- .1:': c "~,-' 1. ',,, "" ,;,.~ ,'=~; < , ,~' '''' , ~ ~ 7. The Plaintiff avers that two children have been born of this marriage. 8. The Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the court require the parties to participate in counseling. 9. The Plaintiff requests the court to enter a decree of di- vorce. 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 P.C.S. ~4904, relating to unsworn falsification to authorities. ~~~.D Al-lN w. YOUN Date: ~\~C\\c)C:l . \ STONE LaFAVER & SHEKLETSKI Be~~: Supreme Court ID #40486 414 Bridge Street, P.O. Box E New Cumberland, PA 17070 Telephone 717-774-7435 Attorneys for Plaintiff -2- II .. " ~ '. ,,' ", .'-,'-, '-" . .' > . "",k",,,~ ' """"', ,,'," ," ',_'n"-' ,_, '_';" ,,;, ,~/." ~ ~,~;'i fl\div\accept.srv .' - .. ~ ANN W. YOUNG, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-6002 CIVIL TERM JGIT:~;'l.A. YOUNG, Defendant CIVIL ACTION LAW IN DIVORCE ACCEPTANCE OF SERVICE I, JAY A. YOUNG, defendant in the above captioned matter, accept service of a certified copy of the Complaint in Divorce filed August 30, 2000 , to the above term and number. 9/1;/00 Date I I JOSEPH . t,,, a (r;- A. 0, 1;:fendant , ,/ Joseph A. Young was mistakenly referred to as Jay A. Young in the Complaint in Divorce filed August 30, 2000, to the above tenn number. I: _~r.~.L', ,,>< "~';' ,. ," "~.~^. ~EH1Wi.l' ~ ,~" ',._, " ~,,"', ,,,," l~L'" " "'......'~ - , M''''':''m''w~ ':'t I:::';' ~ T ~ " "~,' '"~,,~, ,',' , - '",","., ",.,,",#A,'" ". .. '. ,.kc,. ..... " . 0 <::> 0 ~ Cl '" rRm CI) '-j r<1 ;~~;;:: Z::t ." 25>- - 'TIm -""-f""'i CI:l,: co :~~1 -<..~v_ .-::io ~O -0 ;~c:H ~8 3.i:: ~('5 $ ~ c5111 ~ -1 0 ~ 0\ ,,' .',' .,~.. ,'.- 'C~~" "'"i,,,-''' ,,~. ',~ .' ,. , i~i'I~,' fl\div\consent.~ff ANN W. YOUNG, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 00-6002 CIVIL TERM JOSEPH A. YOUNG, Defendant CIVIL ACTION - IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under ~ 3301(c) of the Divorce Code was filed on August 30, 2000. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the complaint and service of the complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. 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 herein are made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to unsworn falsifica- tion to authorities. 11\d.~\Cl \ Date Cl_ '''-l ~ ANN W. YOUNG, l~ff i Ii II II _I."""""""" "'c--,( "il4~~' ~,' .~~, "'-,"". ,., ,'~ "" ,",' ",' ',.' ~. ~" .~". .,,',,' '< , ,-' '. (') c uf~~ nlr~ " ~?"~" r;s;;:-. 2t, ~c:' Zc ).::>c :z _J -< , c,:: c:::J- "'1 .~ co -tJ '0 '" """ ""n =< ~ , \" ,",' .;;,i.,"" \~ "-;' ;:," '.. "i ".\.'[." "i:Lj fl\div\l-waiver ~ ANN W. YOUNG, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-6002 CIVIL TERM JOSEPH A. YOUNG, Defendant CIVIL ACTION LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER ~ 3301(c) 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 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 falsi fica- tion to authorities. I,\~~\a \ Date Q \."-.")"^:Q ANN W. YOUNG, ~ intiff I~L.;""""-"k t ,~ .',"^, ~",.' __ 0.,"""'.' ~ ,-' ,,'. '-~'~' .. '"","," ,~ '",' , ,,~; ':"~'* .;~~""!"~ :J"" ,.,,~'>' ;."> '4, ",,,,,,~,~,,, ".'<_'(Qi ",': ,~, .. ',", .. ... " () r,; ~g~: ,('....",'.' 6j~,~; ~~:~ ~:-Cj ""c -7 ~ '.....'n.. n.... c'::.' o '71 [-) (~ -' "'7] ---"".. 'D ':~ }j ~~ ~~ " " : , . ','0:"""",,", ,; '.c~, ~",""J- , = ,,' ',..", ,"'-, fl \di v\consen\:, aff " - , ANN W. YOUNG, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 00-6002 CIVIL TERM JOSEPH A. YOUNG, Defendant CIVIL ACTION - IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under 3 3301(c) of the Divorce Code was filed on August 30, 2000. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the complaint and service of the complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. 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 herein are made subject to the penalties of 18 Pa. C.S. 3 4904 relating to unsworn falsifica- tion to authorities. JIIJ9!O / . Date "j I i! 'I , I I i! Ii ii I I I I I I' ,I j ii II II " ~ II II " I II II II II 11 " j i! I II i !I 'I ,I I I I I I 'I II I Ii ,I il I 1 'Itf " ,., ~,,;, '>'- ,~,~ ~. W,', '""l5II1lt'~Ji'1*''' .~ li ,,' '. ~ ~" , ,,','- liIiIiI ';'" ',' , o <;; -0;;:. dj~0 ",,-:,,~. -'-- 7r ~~~: r:-,.:.C" ~~Fi )>c :;~ :<: o CJ ;''1 c~ --0 <0 l;; .'- ; ',,,",,, ~'^"':~ ",'" ""'r.' 'j.", ,: ;~": . ", ".,,', Mr::; fl \div\l-Waiver " ANN W. YOUNG, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-6002 CIVIL TERM JOSEPH A. YOUNG, Defendant CIVIL ACTION LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER ~ 3301(c) 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 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 falsifica- tion to authorities. 11/')''1/IJ / Date JOS ~mfli' ~."l"""'" -~ ,~,' f :& u.~i7 ~. ,,.;;;j,."'--~~:a~ihi"fitt,,,.,&;::: :,y - " ."~ ~~"". ",' "" ~~, ". ,.~~ ,- co c...--i c'. 7~ ,-------, -v rJ:' ," ITl ~~ . ,~-; Z 2: en:;.: C1 i~ ~-,;:} :2:: ~ =< ,0 -.: ... :1 I ~ ~' '~ ,.. '" ','~', SOCIAL SECURITY INFORMATION SHEET PURSUANT TO 23 Pa.C.S.A. SECTION 4304.1 (a) (3) ALL DIVORCES MUST INCLUDE THE PARTIES SOCIAL SECURITY NUMBER PLEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN TO THE PROTHONOTARY'S OFFICE DATE: November 28, 2001 DOCKET NUMBER: 00-6002 CIVIL TERM PLAINTIFFIPETITIONER SS# 171-56-0490 NAME: ANN W. YOUNG DEFENDANTffiESPONDENTSS# 179-48-6521 NAME: JOSEPH A. YOUNG "~ ",~r~"~~ ~-". ~" ~ , ,~,~ '.i.'tt!tr, ANN W. YOUNG, * IN THE COURT OF COMMON PLEAS Plaintiff, * CUMBERLAND COUNTY, * PENNSYLVANIA vs. * NO. 00-6002 * JOSEPH A. YOUNG, * CIVIL ACTION - LAW Defendant. * DIVORCE CERTIFICATE OF SERVICE I, Misty D. Lehman, Legal Assistant to Edward J. Weintraub, Esquire, hereby certify that on Apri120, 2001, I served a true and correct copy of an Order and Custody Stipulation entered Apri117, 2001, Gerald Shekletski, Esquire, counsel for the Defendant, by depositing same, postage pre-paid, in the United States Mail, Harrisburg, Pennsylvania, addressed as follows: Gerald Shek1etski, Esquire 414 Bridge Street New Cumberland, P A 17070 Date: ~ ~ 20 -()/ ~- fl~ Mis ~an ';", '~L ~~~"~~.,~,,Ul;~(t~~JiH:::i""."~.O'. - <,~ ~~ .... "'..., '.' -'" "'\ Iij' 'i_~----. g 0 0 - ."f'i !l:: ",.. .-' ~~ -0 ~~I ?O ~~ N -,'JO g:- t'\! ':-=:rtJ CO ~ --c. -y, ~o 'On ..... z5 :i>g e Om ~ c- ?E -J '< iw. ,TO ---.~ -"~~'. . "', .....* ANN W. YOUNG, * IN THE COURT OF COMMON PLEAS Plaintiff, * CUMBERLAND COUNTY, * PENNSYLVANIA vs. * NO. 00-6002 * JOSEPH A. YOUNG, * CIVIL ACTION - LAW Defendant. * DNORCE STIPULATION FOR AN AGREED ORDER OF CUSTODY AND NOW, the parties, by and through their attorneys, stipulate and agree as follows: T LEGAL CUSTODY 1. The parties hereby agree to share legal custody of their minor children, Alex Owen Young born August 7,1992 and Evan Wayne Young born October 1, 1996, All decisions affecting the children's growth and development including, but not limited to: choice of camp, if any; choice of day care provider; medical and dental treatment; psychotherapy, psychoanalysis, or like treatment; decisions relating to actual or potential litigation involving the children, directly or as beneficiary, other than custody litigation; education, both secular and religious; scholastic athletic pursuits and other extracurricular activities; shall be considered major decisions and shall be made by the parents jointly, after discussion and consultation with each other and with a view towards obtaining and following a harmonious policy in the children's best interest. 2, Each party agrees to keep the other informed of the progress of the children's education and social adjustments. Each party agrees not to impair the other party's right to shared legal or physical custody ofthe children. Each party agrees to give support to the other in the role as parent and to take into account the consensus of the other for the physical and emotional well- being of the children. 3. While in the presence of the children, neither parent shall make or permit any other person to make, any remarks or do anything which could in any way be construed as derogatory or uncomplimentary to the other parent. It shall be the express duty of each parent to uphold the other parent as one whom the children should respect and love. 4. It shall be the obligation of each parent to make the children available to the other in accordance with the physical custody schedule and to encourage her to participate in the plan hereby agreed and ordered. " "' ni'n ~~ 5. Each parent shall have the duty to notifY the other of any event or activity that could reasonably be expected to be of significant concern to the other parent. 6. The parents shall communicate directly with one another concerning any parenting issue requiring consultation and agreement and regarding any proposed modifications to the physical custody schedule, which may from time to time become necessary, and shall specifically not use the children as a messenger. Furthermore, neither parent shall discuss with the children any proposed changes to the physical custody schedule, or any other issue requiring consultation and agreement, prior to discussing the matter and reaching an agreement with the other parent. 7. With regard to any emergency decisions which must be made, the parent with whom the children are physically residing at the time shall be permitted to make the decision necessitated by the emergency without consulting the other parent in advance. However, that parent shall inform the other of the emergency and consult with him/her as soon as possible. Day-to-day decisions of a routine nature shall be the responsibility of the parent having physical custody at the time. 8. Each parent shall be entitled to complete and full information from any doctor, dentist, teacher or authority and have copies of any reports given to them as a parent. Such documents include, but are ~'ot lilnited to, medical reports, academic and school report cards, birth certificates, etc. Both parents may and are encouraged to attend school conferences and activities. The Father's name shall be listed with the school as the alternative parent to be contacted in the event of an emergency and to be notified regarding school events. However, it will be Mother's primary responsibility to provide Father with copies of report cards and all notifications of major school events. 9. Neither parent shall schedule activities or appointments for the children which would require their attendance or participation at said activity or appointment during a time when she is scheduled to be in the physical custody of the other parent without that parent's express prior approval. 10. The parties hereby acknowledge that they have discussed and jointly made the following decisions: a. The parties agree that Ryder/Barnes Associates will continue to be the children's pediatrician and accordingly, will provide medical treatment to the child when necessary. 2 '" ..i", , , ,~ ., ,'" b. The parties acknowledge that the children's legal name are Alex Owen Young and Evan Wayne Young and that they shall be known by these narne(s) for all purposes. The parties agree that they will instruct their respective families and friends that the children should not be referred to by any other name. II PHYSICAL CUSTODY The parties shall share physical custody of both children. Mother shall have primary physical custody and Father shall have partial physical custody as they may mutually agree. Failing mutual agreement to the contrary, the following schedule shall apply: 1. Alternating weekends with Father commencing with the adjoumment of school on Friday and concluding with the delivery of the children to school or day care on Monday morning at 8:00 a.m. 2. Preceding Mother's custodial weekends, a mid-week overnight visit with Father from Thursday upon the adjoumment of school until 8:00 a.m. Friday the following morning. 3. All Monday holiday's such as Memorial Day, Labor Day, Martin Luther King Day, Veterans Day, Columbus Day, President's Day and deer hunting Monday after Thanksgiving shall be tacked onto the preceding alternating weekend, thereby extending that parties alternating weekend until Tuesday morning at 8:00 a.m. 4. The Christmas vacation shall be divided into two segments; the first commencing with the adjournment of school and continuing until December 25th, Christmas Day, at noon; the second segment commencing at noon on Christmas Day and continuing until 6:00 p.m. until the evening before school resumes in January. Mother shall have the first segment in 2000 and Father shall have the second segment in 2000 and the segments shall be reversed and alternated annually. 5. The Thanksgiving holiday will be divided into two segments; the first commencing on Wednesday with the adjournment of school and continuing until Thanksgiving Day, Thursday, at 2:00 p.m.; the second commencing at 2:00 p.m. on Thursday and continuing until Friday at 6:00 p.m. Father shall have the first segment in 2000, 3 . , .. , ~. ", '- ~. Mother shall have the second segment in 2000 and they shall be reversed and alternated annually. 6. Spring vacation from the adjournment of school until 6:00 p.m. on the evening before school resumes shall be alternated annually, except that Mother shall have Easter Sunday from 9:00 a.m. until 6:00 p.m every year. 7. During the surnmer, between the adjournment and resumption of school, each parent shall have twenty-one (21) days of vacation time with both children simultaneously, to be exercised in three (3) seven (7) day blocks, one week with each parent in June, one July and one week in August. Vacation days may be regular period of custody, but shall not schedule. Both parties shall time each week in tacked onto any other conflict with the other parents holiday give the other sixty (60) days notice of any vacation wishes to designate. 8. Father's Day weekend from the adjournment of school until Monday at 8:00 a.m. with Father every year. 9. Mother's Day weekend from the adjournment of school until Monday at 8:00 a.m. with Mother every year. 10. Bach parent shall have physical custody of the children for attendance at family funerals, near death situations and at weddings with reasonable notice to the other parent. III. TRANSPORTATION The parent whc is receiving the children shall be responsible for the transportation. IV TELEPHONE PRIVILEGES The parties ag"ce L1at there shall be reasonable telephone access between the children and both parents. The parents are encouraged to place telephone calls to the children between 6:00 p.m. and 8:00 p.m. so as not to interfere with dinner or bedtime. The child shall be permitted free access to place calls to her parents at any time she desires. V RELOCATION The parties have negotiated the custody and partial custody portions of this Agreement based upon existing circumstances, and in particular, based upon Wife's and Husband's current residences in Cumberland County, Pennsylvania. If either parent desires to establish a residence more than fifty 4 , ,. > (50) miles from his or her present residence, he or she shall give the other parent at least ninety (90) days' written notice in advance of the proposed move, in order to give the parties the opportunity to confer, prior to the relocation, and to establish a mutually satisfactory arrangement as to custody and partial custody in light of the changed circumstances. In the event that the parties are unable to reach an agreement, then the Court of Common Pleas of Cumberland County shall have jurisdiction over them to fashion an appropriate custody/partial custody order. 5 ,..._"~ " ~ "">l:.iII'" 'lliHr, This Stipulation shall be entered as an Order of the Court. Jay Edwar . Weintraub, Esquire Attorney for Plaintiff Gerald Sh etski, Esquire Attorney for Defendant J. Date:~ 11l 2(jV \ ~ ..~ t~'\1{)\ 1-\1 6 II ii, '>- Cl i:= t; e: p Z N ::J .~ C) '~ , ., :'-2 . .::) :;~ , ., -' , ::.J C'J C/) -7 ,'~. 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