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Home My WebLink About00-06199 .", .1 . . . . . :f. :f.:f.:f.:f.:f. :f.:f. :f. m:f. m:f. m:f. :f.m :f.:f.:f.:f.:f.:f.m m . . IN THE COURT OF COMMON pLEAS , OF CUMBERLAND COUNTY . . PENNA. . STATE OF . . HARo~n R TRWTN. 111, . No. 00-6199 CIVIL TERM Plaintiff VERSUS GAY L. IRWTN, . npfpnn;:ant- . . . . DECREE IN DIVORCE . . . . . AND NOW, December :z.l 2000 , IT IS ORDERED AND DECREED THAT HAROLD S. IRWIN, III , PLAINTIFF, . AND r.l\V T. 1~WIN , Df:FENDANT, . ARE DIVORCED FROM THE BONDS OF MATRIMONY, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; . . NONE . . . . m:f. mm . . . . . . ATTEST . . . . . . m:f. :f. mmm:f.:f. .. m:f. m:f. m ,,,. t'..",.--", ",,"',' , '"' 1~'. . 'e', <";..O;;';'F"'. ,'C.,> ,," J, . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . "'-, ';~~'''''-''''_1J:ilaIli~''-~''.H...o&iJ_'-''ilij& iIW~~:I o..._.~.iIIIit'.....~....,:. ~ ~I .~ , .. -;~. . " <',. 1~.~/.t:J~w<~~~4~ /d-.;l.I'O.&~ ~ ~..4~ .".L."'~. "~ ,~ L ,. , M HAROLD S. IRWIN, III SUPREME COURT ID "0 29920 35 EAST HIGH STREET CARLISLE PA 17013 (717) 243-6090 HAROLD S. IRWIN, III, Plaintiff : IN THE COURT OF COMMON fLEAS OF : CUMBERLAND COUNTY, PEN",SYLVANIA : v. : CIVIL ACTION - LAW : NO. 00 - 6199 CIVIL TERM GAY L. IRWIN, Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD Please transmit the record, together with the following information, to the court fon entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under Section 3301 (c) of It he Divorce Code, 2, Date and manner of service of the complaint: On or about S~ptember 14, 2000, defendant was served by certified mail, return receipt requested, with a copy of the divorce complaint. See Affidavit of Service filed by plaintiffs counsel. ! 3. Complete either paragraph (a) or (b): (a) Date of execution of the affidavit of consent required by Secti9n 3301 (c) of the Divorce Code: By the plaintiff: DeClfmber 14, 2000 By the defendant: Dec$mber 14, 2000 (b)(1) Date of execution of the affidavit required by Section 3301 (d) ~f the Divorce Code: N/A (b)(2) Date of filing and service of the plaintiffs affidavit upon the de~ndant: N/A. 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: N/A (b) Date plaintiffs Waiver of Notice in Section 3301 (c) Divorce was fil~d with the Prothonotary: December 14, 2000 Date defendant's Waiver of Notice in Section 3301 (c) Divorce wasi filed with the Prothonotary: December 14, 2000 . HAROLD S. IRWIN, III ESQ Attorney for Plaintiff December 14, 2000 I'~ . '":"I'7,"',e,__.;~,, ,"C'~'O" .,' ;"'~"~!,~ .'~",,", ',n.,_ ., !"e ., h~.. -.. r "~'~"""'~~'> "-' ..' o~~ ,w""-,_,, ~ " ",">'<J""'" '='~&^ ...... .. I~_, Jl,~~.=", ~-~?, ~,.-~. o c s: -om m!I) Z.~',} z~:: C/J.,e.;,. -<.0 ~.:~: z(~; >c 7" -< ''''<'----'I''n' o o CJ P"I CJ o -n -'1 1= ~:~s9 :-::~ ~~) ,'--,', :~;? ~;~ ~~ ~ -< c'- -)'"'1', ~--;'J~ - , ;,.....- eo ~. ,,-,1lJilI~~ .. -~, ,~ I. :.IN THE COURT OF COMMON 'LEAS OF : CUMBERLAND COUNTY, PENINSYLVANIA HAROLD S. IRWIN, III, Plaintiff v. : CIVIL ACTION. LAW = NO. 00 . ~ /99 CIVil TERM GAY L. IRWIN, Defendant : IN DIVORCE NOTICE 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 in divorce or anrhulment 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 divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriag~ counselors is available in the Office of the Prothonotary, Cumberland County Coul1house, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR At--lNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. . YOU SHOULD TAKE THiS PAPER TO YOUR LAWYER AT ~NCE. IF YOl.: DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO O~ TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAiN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-243.3166 " .~. , .. .~~~" .' ." --""=:"',~.,,",,' ,"' -'" :~ ~'i' . , ~ " .. ..... I, HAROLD S. IRWIN, III, Plaintiff : IN THE COURT OF COMMON fLEAS OF : CUMBERLAND COUNTY, PEN,.SYLVANIA v. : CIVIL ACTION. LAW : NO. 00. (,/99 CIVIL TERM GAY L. IRWIN, Defendant : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301 ~ OF THE DIVORCE CODE NOW, comes the plaintiff and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is Harold S. Irwin, III, an adult individual residing at 606 Mooreland Avenue, Carlisle, Cumberland County, Pennsylvania 17013, 2. The defendant is Gay L. Irwin, an adult individual residing at 606 Mooreland Avenue, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The plaintiff and the defendant were married on December 8, 1973, in Perry County, Pennsylvania. ~,.'U"V;"',"'~ _,..,. -,,;.J.,~~~.;-\:""~:""'''..~ ",,,.,,,...< ',. ',,"," , '_wo.".,. .' .~ .w ." '" ,__" = ,"'~' 5. Pursuant to the Divorce Code, Section 3301(c), the plai~tiff avers as the grounds upon which this action is based that the marriage betweeh the parties is irretrievably broken. 6. The plaintiff avers that he has been advised of the availability of counseling and that he has the right to request that the court requi~e the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the m~rriage between the two parties. I verify that the facts contained herein are true and correct. I 'understand that false statements herein made are subject to the penalties of 18 Pa. C. 'S. Section 4904 relating to unsworn falsification to authorities. September 11, 2000 ''WO ",..' . '?' .,., '" .-----~<, ""';.'~" ,., --."' "'!"". ": ',. '.~ A. .,.. '" ",,~ ."cc. ,.. ,,, HAROLD S. IRWIN, III, Plaintiff I , : IN THE COURT OF COMMON fLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : NO. 00 - (, 1'?9 CIVIL TERM GAY L. IRWIN, Defendant : IN DIVORCE PLAINTIFF"S MARRIAGE COUNSELING A~FIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. e.s. Section 4904 relating to unsworn falsification to authorities. September 11, 2000 laintiff ". ".., ",-,"' ",'~"""~,,:n --'''''/,~,' ",I":" '"" "~'r"'~" ..-,,' ',.. ,,", . ,.. HAROLD S. IRWIN, III, Plaintiff I : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PEN~SYLVANIA v. : CIVIL ACTION - LAW : NO. 00 - 6199 CIVIL TERM GAY L. IRWIN, Defendant : IN DIVORCE DEFENDANT'S MARRIAGE COU,NSELlNG AFFU)A VIT The defendant, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. understand that false statements herein made are subject to the penalties of 18 Pac C.S. Section 4904, relating to unsworn falsification to authorities. December 14, 2000 ~ ), II ii il il I" II II, i~ II Iii b " i" I:' """""~ . .lllf)llJllM,~." ~,~!!!I~. ,., ."" .. ",~1\Il' ~~.. " 0 0 0 C 0 --'1 $': 0 ~:;J -0 OJ Pl 9Jf+J '> -;11"1] ~S;' ~!-:-~ ~;~8 ~.,.:::: ~,?S,~ ~C:' ::r~ " <, P0 :z ;J""'il 2:C: - :":0 PC' - f~rTl 2: ;::,,) ~ ---j :::a -< ();) -< ,~r'~' f1 '.'", ..~ HAROLD S. IRWIN, III, Plaintiff = IN THE COURT OF COMMON ~LEAS OF = CUMBERLAND COUNTY, PENjIISYLVANIA v. = CIVIL ACTION. LAW = NO. 00 - 6199 CIVIL TERM GAY L. IRWIN, Defendant = IN DIVORCE PLAINTIFF"S MARRIAGE COUNSELING AF~IDAVIT 1. I have been advised of the availability of marriage ~ounseling and understand that I may request that the court require that my spouse anti I participate in counseling. 2. I understand that the court maintains a list of marriage c~>unselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require Ithat my spouse and I participate in counseling prior to a divorce decree being handed d~wn, I verify that the statements made in this affidavit are true and correct. IlUnderstand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authori ies. December 14, 2000 "" ~--"_'-~'-_',~,: ""~ ,,,<, .'O^'I_'. ,'''~,,,,,, " ~ 1- ."""",,~,,' "'If'. qflt!~~,...,.":",l,~ ',~ ~,.r . (') r .:,:=; '- -063 rn fTI Z::rJ zr- (j)d:: ~6 "'- ~-"'c-::, Zo 5>c::: z ::2 . ,~ -L .,~ o a c:;l ,''1 n C) -,j , lC;::::; '~2f24 .1'.....- ~..... L :<c; ~1~ "00- ~ .i;- ~~~ ...,;"'- ~ OJ ",.,lm,,,,,,,,"!, """.,r HAROLD S. IRWIN, III, Plaintiff : IN THE COURT OF COMMON LEAS OF : CUMBERLAND COUNTY, PEN SYLVANIA v. : CIVIL ACTION - LAW : NO. 00 - 6199 CIVIL TERM GAY L. IRWIN, Defendant :IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAIN'lr PURSUANT TO PA. R.C.P. RULE NO. 1920.4 ~ NOW, Harold S. Irwin, HI, Esquire, being duly sworn accordirjtg to law, does depose and state: 1. divorce. That he is a competent adult and plaintiff in the above caliltioned action in 2. That a certified copy of the complaint in divorce was s~rved upon the defendant on or about September 14, 2000, by certified mail "res~ricted delivery", addressed to the defendant at 606 Mooreland Avenue, Carlisle, PA 17013 (Certified Mail Receipt No. 7099 3220 0011 0097 6635. 3. That a copy of the sender's receipt and signed receipt for certified mail is attached hereto. I verify that the statements made in this affidavit are true ~nd correct. I understand that false statements herein made are subject to the penalties of 18 Pa, C. S, Section 4904, relating to unsworn falsification to authorities. Harold S. Irwin, III September 15, 2000 ;, ""I ,,' .',. "'i''7'~.'''"' ""~":~"",W"',.~"~,,,., --"', 'F"""""~,""., ., ."C;'mP1~e,il ii'$l;~;"ndg. )\~oC<;;"pi;;;~ item 4if'ReS\rlqledDelivery Is desired. . Print your rname. alld address on the reverse so that we ,can return the card to you. . . Atl,jph this card to the back of the mailpiece. . or oQ the front if spaee permits. 1. Article AdiJreSsed to: (9~J:/ /.,. I J..t.JI,I (.II(, IYItJlJ~t/.AJJ(J I/vt ~.'..JIl.i1J.I. 15ct;t 17~/J '.ft1I- -;, . Is deli ry ad different from item 1? If YES. enter delivery address below: l( 3. SalVies Type ~ Certified Mail 0 Express Mail b~Registered ~etum Receipt for Mefchandisec [J Insured Mail 0 C.C.Q. 4. Restricted Delivery? (EXtra Fee) Vas 2. Articfs_ Nl;!,mber (Copy from service label) '1'f.11f;l6 a4"~ MrfC PS Form 3811. July 1999 DomOSlloROlurn R_pt , 1025~5-99.M.1789 ,~__I_.._- - U.s p , CERl,., . . (Domestic Mall Only No Insurance GOVt;;:Iclge Ptovlded) Ul en ..D ..D r- IT' C C Postage $ , Certified Fee CJ I. Z-S .~ ,;). 7S $ S.fS- Postmark H". RetUIIf1 RecelptF=ee r=t (Endorsement Required) .-'I , C Restricted Delivery Fee C {Endorsement Required) Total Postage & Fees C nJ nJ en IT' IT' C r- :;:J.. "'~"""-'" ',' -,~"",'. ~,' .. , " "~ --,., , M'" "<<oC~",,". , . I I I I I I J - , .~,' :' '''~"."'"' " "..~ ,_." ,-~,"" - , ,.;-".' , '^',,""'", " ~. '. ,. 2 _is: --"OJ ~$ t&'5c. ~6 !g ~ "" --Iii 'C~ C;) 'n ,:." 'V "'-", u ." --..1 ~,'" ~., '. , . ~ f~:,;, JI? --'4> - "'1'"-rJ ~o iSm 35 -< en -0 :1: ~? l'\) f\) ~ ~'M ,~ .~~,'~ ~. ~~",....~~ - e' ~~ HAROLD S. IRWIN, III, Plaintiff ; IN THE COURT OF COMMON PLEAS OF ; CUMBERLAND COUNTY, PENNSYLVANIA v. ; CIVIL ACTION - LAW ; NO. 00 - 6199 CIVIL TERM GAY L. IRWIN, Defendant ; IN DIVORCE PLAINTIFF"S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed in this matter on or about September 11, 2000 and served upon the defendant on or about September 14, 2000. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsific ion to authorities. December 14, 2000 HAROLD S. IRWIN, III I:jt'r~::, ^ 10. . '- ,<-c.", <'. "",<..~,,,. "" '__'" J',. ': ,,', ,. _', __ , ,,]" ',--,,-"" ". """ ',,' ~,.I <>1 I i , ~ ! " ~ ! Ii Ii [, ~ J.I + _. ~, '" ",",,,I).'~"= '".~~~~~ - ""I 0 a 0 C a " ~. s... C) :._::...l. u cD r" nlr-;--J n ~:;:. ......" ~f' .,;::::-:;; f7l ~~-~ ,,::- ,~S ~I~ C;; ~:~~ :i:;:..." ~~~ Pc ~P' ~C) - Pc:: - ~ , , ~ ' , '~ :n 0:> -< ". T ~llll1!l;llllll!!1!f~~'" ~ ~_. ,.". HAROLD S. IRWIN, III, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . . v. : CIVIL ACTION - LAW : NO. 00 - 6199 CIVIL TERM GAY L. IRWIN, Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTIONI0 REQUEST ENTRY OF A DIVORCE DECREE UNDE~,SECTION 3301 lID OF TI1E DIVORCE CeDE 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. Section 4904 relating to unsworn falsification to authorities. December 14, 2000 , ~, ~. ..~ :1 :1 " ,^ 1 ".m~'~"'"'.i " ~, ~ > - ~' , ,-- ~~ .",~ ,',0<" "l ~. ~H,,<' '''. _', " <:) S ~~ -r) 0:3 rnrTi :Z:J:~I ZC C0,.,F:~ ;::;~i <.c"'L- ~c:; __(~l >c Z =<! Cl Cl Cl P"1 C) n ..:::r, --, i~~ .-~ " (~~ ~."",l .J C5rl1 :;;i ~ ,," '~ .- ~ -;0., w (JO l;~,~.""'"f'"',~~''''''~''-''''"''-'"''''~'~~''''''''' ~ '" HAROLD 5. IRWIN, III, Plaintiff ; IN THE COURT OF COMMON PLEAS OF ; CUMBERLAND COUNTY, PENNSYLVANIA v. ; CIVIL ACTION. LAW ; NO. 00 - 6199 CIVIL TERM GAY L. IRWIN, Defendant ; IN DIVORCE DEFENDANT'S AF'FI:DAVIT OF CONSENT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed in this matter on or about September 11, 2000 and served upon defendant by certified mail on September 14,2000. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. understand that false statements herein made are subject to the penalties of 18 Pa, C. S. Section 4904 relating to unsworn falsification to authorities. December 14, 2000 h. ~'. < -", .~ I" '..n, ' . ~ ~ ~- ".,.JIllIIIIIUIIl (') C) 0 c a ~ "Tj Cl ""Uv' rq ;7;~ ITlr;=;-! Z:i-,i " . ':.:;"~ ~~. ~ I~tE f2Ci (:-?..,L, :;;;:... .c:J'~' P.---.~ .~ '''J:i:J 7\,..; =0 :::;..C) Pc orn ~ :.:> c;;! 0::> :0 -< ~~,~" ""~!I.!m__,,,,<li "I'~"-' Uti] ~,:'aIfij~1,." . I HAROLD S. IRWIN, III, Plaintiff = IN THE COURT OF COMMON PLEAS OF = CUMBERLAND COUNTY, PENNSYLVANIA v. = CIVIL ACTION - LAW = NO. 00 - 6199 CIVIL TERM GAY L. IRWIN, Defendant = IN DIVORCE WAIVER OF NOTICE OF liNTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301ml 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. Section 4904 relating to unsworn falsification to authorities. December 14, 2000 (" . " -.""","'.' ,<', .c,. -'-""'; -, -.~" , ,. '" I .~" ~ ' "' """ ., .,~." ~"r/" H "' ~-. -,., ""'",,.,,-,,', ., ,~~ " , i ~"'-"I-' --- --,,, -" (') 0 0 c 0 -n :;;: 0 " "fl OJ ;-'q -.r~ m ~ C") '~l ::~-,! Z " ZI;:' -~:;';:q (/5,.,:', '- ..:< '..... -<cc. .' ,--, r::::~=: '-..-" :J~' ;, 3>0 ::i.: i,'5 C) ZCl ~rn Pc Z (".) ~ 00 -< .,"'~~~;..c "'"'~''''TIl!9~1''''''''- NIWl1l!~~~~~ -"',~,. HAROLD S. IRWIN, III, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND C()UNTY, PENNSYLVANIA v. : CIVIL ACTION. LAW : NO. 00.6199 CIVIL TERM GAY L. IRWIN, Defendant : IN DIVORCE ORDER OF COURT ~ AND NOW, thi~ day otIJov: , 2000, upon presentation and consideration of the attached stipulation and agreement and upon agreement of the parties, it is hereby ordered and decreed that the attached agreement is made an Order of Court. BY THE COURT, J. '""'-,;'11 -.' ,.' -_-':-',,'7~.:-,,-_-, -fr"-.-j'~ "",.,,-,,<"~, .', ,< '1" '~~. ~-'r1"" - ,~ - . "". - ,f ~1I.'il~lli_~~~~~"'-'" [t...ilitiiliUiIlItl' '.'1.__ =..,,~ ~" .~'" .~=. _ ~., L.~ -""Cc P\ FD-Orr\ '- W 'T':::: - [YJ"I:,J,ONOIflh I Or ,;" 1 ,,', 00 N[)\.l - \ Pl'\ 3: 13 CUMB\:.R\J>ND couNTY PE\\\NS'(lVAN\i\ ,,"'"~ ,..^ .~ ,'~~'. 'n,"',=; ",'" ",fl" , . - - "~ ,,1 'j ''j? , "(l ~ '- 'll }J "" HAROLD S. IRWIN, III, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : NO. 00 - 6199 CIVIL TERM GAY L. IRWIN, Defendant : IN DIVORCE STIPULATION AND AGREEMENT THIS STIPULATION AND AGREEMENT entered into this Z?~ay of October, 2000, by and between HAROLD S. IRWIN, III (hereinafter referred to as "Father") and GAY L. IRWIN (hereinafter referred to as "Mother"). NOW THIS AGREEMENT WITNESSETH THAT: WHEREAS, the Father and Mother are the natural parents of one (1) minor child, namely, Zachary J. Irwin, born September 3, 1984; and WHEREAS, the parties wish to enter into an agreement relative to the custody and partial custody of the child. NOW, THEREFORE, in consideration of the mutual covenants, promises and agreements as hereinafter set forth and intending to be legally bound, the parties hereto agree as follows: 1. The parties shall have joint legal custody of the child. 2. The parties shall also share primary physical custody of the child as the parties may mutually agree, with the parties agreeing to cooperate fully to coordinate " ,. "'T- .' , ~--,., .. ,.t.,'., -,' these temporary physical custody times and to share holiday time and vacation time with the child. It is the intention of the parties to share time with the child on as much of an equal basis as possible, provided that intention remains compatible with the wishes, schedule and other activities of the child, which both parties agree are of primary concern in making these arrangements. 3. Provided that the parties continue to share time with the child on a relatively equal basis, the Father will pay to the Mother the sum of $75.00 per week for the support of the child while he is in her custody. Father shall also continue to provide medical insurance coverage for the child. The parties agree that the Father shall be entitled to the dependency exemption for the child on Father's individual income tax returns. 4. The parties will keep each other advised immediately relative to any emergencies concerning the child and shall further take any necessary steps to ensure that the health, welfare and well being of the child is protected. 5. The parties shall do nothing that may estrange the child from the other parent or injure the opinion of the child as to the other parent or which may hamper the free and natural development of the child's love or affection for the other parent. 6. Any modification or waiver of any of the provisions of this agreement shall be effective only if made in writing and only if executed with the same formality of this agreement. 7. The parties agree that in making this agreement there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other. 8. The parties desire that this agreement be made an order of Court through the Court of Common Pleas of Cumberland County, and further acknowledge that the ~",.:''F'''~'J .'-~ '" --'''''"'''~.'':''''''C: ",...."P','.'L , ~.r "'~ . ". ~,1 ,~ " . '~""'"" ,",. """', '," ,-~ , ~ , ~._~.- Court of Common Pleas of Cumberland County has jurisdiction over the issue of custody of the parties' minor child and shall retain such jurisdiction should circumstances change and either party desire further or require further modification of said Order. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound by the terms hereof, set forth their hands and seals the day and year herein set forth. WITNESSETH: Date:~Q (SEAL) ~x Ccr Date: kJjlSto<> 04/ iJ---t~ (SEAL) '.1 " " ~.~ '" , .' ,~ ~i'",>, """"c', "\"W '''.,:'f'';~ ,.' "1, " n, ~q, ,.': ~, "=,, ,_. ,r " ,,0 ~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND :SS: PERSONALLY APPEA~D BEFORE ME, a notary public for Cumberland County, Pennsylvania, this ~ day of October, 2000, HAROLD S. IRWIN, III, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within agreement, and acknowledge that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal, NOTAIUA&. HAL """~IE L. COYU, NOTARY PUBUC c::AIIUSLI, CUMBERLAND COUNTY . .~SION I!llPtAn OCTOBeA 11 2002 &~~~ Notary Public 1 COMMONWEALTH OF PENNSYLVANIA COUNTYOF ~ :SS: PERSONALLY APPEARED BEFORE ME, a notary public for Cumberland County, Pennsylvania, this~-3,g!.. day of October, 2000, GAY L. IRWIN, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within agreement, and acknowledge that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. ~y~ Notary Public . NOTAIUA&. HAL 80NIlIE L COYU, NOrMY PUBUC BOAG or CAIIU8LI, ClIM8EIILANO COUNTY MY COMMIUION _nOCTOSEA t1 2002 ~,? ~ 1''' ^ ',~'.T~"~~'--"C~f""/';"",,;',~~' ,,-,y,.o;'i'''~ " ., . ;', ,','" .~ '" L ~"'" . _ , ,~, "~ r~ . ~ """ \:>"- N ~ -tI ";) --C , .,.. ,- I.~ . -~ ~".,~.1l'J; "\- ~, .~. -- - " o ~~ -DC, rnr'~ Z:'i' 0~~" r~- c', -'- , .;.-~ ,':< , ""'--~ -'-' ':,::') 'CO-) ''-~l ~<.' {; J..",", .....,: "~~~".' ,,,,~"_.,. ''''h -, ~"i_' --..:;., ~ .. 1l,:, <>- ~ t1 t t t ~~~WI';'M<!lI'i!J!;!I~~lm1i:l1~~, r~,'~n" '_"!"~IlI~w,<lQ~