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IN THE COURT OF CbMMON PLEAS
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OF CUMBERLAND COUNTY
STATE OF PENNA. .
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DALE L. ROBINSON,
No. 2000-8434 CIVIL TERM
Plaintiff
CIVIL ACTION - LAW .
VERSUS
LISA M. ROBINSON, IN DIVORCE
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Defendant
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DECREE IN
DIVORCE
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AND NOW, ""'7 .z;!.~ , 2002 , IT IS ORDERED AND .
DECREED THAT DALE L. ROBINSON , PLAINTIFF,
AND LISA M. ROBINSON , DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISEO OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
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The Marriage Settlement Agreement dated May 8, 2002 and signed by the
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parties is hereby incorporated into this Decree, but not merged.
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PROTHONOTARY
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MARRIAGE SETTLEMENT AGREEMENT
THIS AGREEMENT made this 'a~ day of May, 2002, by and between LISA M.
ROBINSON, (hereinafter referred to as "WIFE") and DALE L. ROBINSON, (hereinafter
referred to as "HUSBAND").
WITNESSETH:
WHEREAS, HUSBAND and WIFE were lawfully married on November 20, 1993, in
Carlisle, Cumberland County, Pennsylvania. HUSBAND filed a Complaint in Divorce in
Cumberland County, Pennsylvania, docketed at 2000-8434 Civil Term on December 5, 2000.
The parties hereto agree and covenant as follows:
1.
The parties intend to maintain separate and permanent domiciles and to live apart from
each other. It is the intent and purpose of this Agreement to set forth the respective rights and
duties of the parties while they continue to live apart from each other.
2.
The parties have attempted to divide their matrimonial property in a manner which
conforms to a just and right standard, with due regard to the rights of each party. It is the intent
of the parties that such division shall be final and shall forever determine their respective rights.
The division of existing marital property is not intended by the parties to constitute in any way a
sale or exchange of assets.
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3.
Further, the parties agree to continue living separately and apart from the other at any
place or places that he or she may select as they have heretofore been doing. Neither party shall
molest, harass, annoy, injure, threaten or interfere with the other party in any matter whatsoever.
Each party may carry on and engage in any employment, profession, business or other activity as
he or she may deem advisable for his or her sole USe and benefit. Neither party shall interfere
with the uses, ownership, enjoyment or disposition of any property now owned and not specified
herein or property hereafter acquired by the other.
4.
The consideration for this contract and agreement is the mutual benefit to be obtained by
both of the parties hereto and the covenants and agreements of each of the parties to the other.
The adequacy of the consideration for all agreements herein contained is stipulated, confessed,
and admitted by the parties, and the parties intend to be legally bound hereby.
Each party to the Agreement acknowledges and declares that he or she, respectively:
(a) is represented by counsel of his or her own choosing;
(b) is fully and completely informed of the facts relating to
the subject matter of this Agreement and of the rights
and liabilities of the parties;
(c) enters into this Agreement voluntarily after receiving the
advice of counsel;
(d) has given careful and mature thought to the making of this
Agreement;
(e) has carefully read each provision of this Agreement; and
(f) fully and completely understands each provision of this
Agreement, both as to the subject matter and legal effect.
This Agreement shall become effective immediately as of the date of execution.
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5.
It is the purpOSe and intent of this Agreement to settle forever and completely the interest
and obligations of the parties in all property that they own separately, and all property that would
qualifY as marital property under the Pennsylvania Divorce Code, Title 23, Section 401(e), and
that is referred to in this Agreement as "Marital Property", as between themselves, their heirs and
assigns. The parties have attempted to divide their Marital Property in a manner that conforms to
a just and fair standard, with due regard to the rights of each Party. The division of existing
Marital Property is not intended by the parties to constitute in any way a sale or exchange of
assets, and the division is being effected without the introduction of outside funds or other
property not constituting a part of the marital estate.
It is the further purpose of this Agreement to settle forever and completely any obligation
under the Pennsylvania Divorce Code relating to spousal support or alimony.
6.
Each party represents and warrants that he or she has made a full and fair disclosure to the
other of all of his or her property interests of any nature, including any mortgage, pledge, lien,
charge, security interest, encumbrance, or restriction to which any property is subject. Each
party further represents that he or she has made a full and fair disclosure of all debts and
obligations of any nature for which he or she is currently liable or may become liable. Each
further represents and warrants that he or she has not made any gifts or transfers for inadequate
consideration of Marital Property without the prior consent ofthe other.
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The parties have heretofore filed joint Federal and State tax returns. Both parties agree
that in the event any deficiency in Federal, State or local income tax is proposed, or any
assessment of any such tax is made against either of them, each will indemnifY and hold
harmless the other from and against any loss or liability for any such tax deficiency or
assessment and any interest, penalty or expense shall be paid solely and entirely by the individual
who is [mally determined to be the cause of the misrepresentations or failures to disclose the
nature and extent of his or her separate income on the aforesaid joint returns.
7.
REAL ESTATE: The parties owned no real estate at the time of the signing of this
Agreement.
8.
WARRANTY AS TO EXISTING OBLIGATIONS: Each party represents that they
have not heretofore incurred or contracted for any debt or liability or obligation for which the
estate of the other party may be responsible or liable except as may be provided for in this
Agreement. Each party agrees to indemnifY and hold the other party harmless for and against
any and all such debts, liabilities or obligations of every kind which may have heretofore been
incurred by them, including those for necessities, except for the obligations arising out of this
Agreement.
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9.
WARRANTY AS TO FUTURE OBLIGATIONS: HUSBAND and WIFE covenant,
warrant, represent and agree that, with the exception of obligations set forth in this Agreement,
neither of them shall hereafter incur any liability whatsoever for which the estate of the other
may be liable. Each party shall indemnify and hold harmless the other party for and against any
and all debts, charges and liabilities incurred by the other after the execution date of this
Agreement, except as may be otherwise specifically provided for by the terms of this Agreement.
10.
SPOUSAL SUPPORT: It is the mutual desire of the parties that HUSBAND will not be
required to pay alimony to the WIFE for herself following the entry of the Divorce Decree in
this case. WIFE will not provide any financial support or alimony to the HUSBAND. The
current spousal Order will terminate on May 15,2002.
11.
PERSONAL PROPERTY: The parties agree that the personal property shall be divided
as follows:
HUSBAND shall receive the following items:
( a) The personal property in his possession.
(b) His bank accounts;
(c) Any life insurance policy;
(d) His employee benefits; and
(e) The sum of Four Thousand Five Hundred Seventeen and 73/100
($4,517.73) Dollars from the escrow funds at M&T Bank.
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WIFE shall receive the following items:
( a) The personal property in her current possession.,
(b) Her bank accounts;
(c) Any life insurance policy;
(d) The wedding photograph album; and
(e) The sum of Six Thousand Seven Hundred Seventy-Six and 60/100
(6,776.60) Dollars from the M&T Bank escrow account.
The WIFE hereby waives all right and title which she may have in any personal property of the
HUSBAND. HUSBAND likewise waives any interest which he has in the personal property of
the WIFE. Henceforth, each of the parties shall own, have and enjoy independently of any claim
or right of the other party, all items of personal property of every kind, nature and description
and wherever situated, which are then owned or held by or which may hereafter belong to the
HUSBAND or WIFE with full pOwer to the HUSBAND or the WIFE to dispose of same as
fully and effectually, in all respects and for all purposes as if he or she were unmarried.
Each party agrees that neither will incur obligations, liens or liabilities on account of the
other and that from the date of this Agreement, neither party shall contract or incur obligations,
liens or any liability whatsoever om account of the other.
12.
AUTOMOBILES:
(a) HUSBAND agrees to waive any and all interest which he may
have in the automobiles in possession of the WIFE.
(b) WIFE agrees to waive any and all interest which she
may have in the automobiles in possession of the HUSBAND.
They each waive any claim which they have in any automobile owned by the other party.
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13.
INSURANCE, EMPLOYEE BENEFITS AND INCOME TAX EXEMPTIONS: The
parties agree that any life insurance policies on the life of HUSBAND or WIFE or any other
employee benefits, including but not limited to retirement, profit sharing or medical benefits of
either party, shall be their own. The parties agree that WIFE will be entitled to claim Paige M.
Robinson, born March 14, 1996, six (6) years of age, each year as her Federal income tax
exemption.
14.
BENEFITS AND BANK ACCOUNTS: WIFE agrees to waive all right, title and
interest which she may have in the savings or checking or any other bank accounts of the
HUSBAND. The HUSBAND agrees to waive all interest which he has in the bank accounts of
the WIFE.
15.
DIVORCE: The parties both agree to cooperate with each other in obtaining a [mal
divorce of the marriage. It is agreed that the parties will execute and file the consents necessary
to obtain the divorce. Any party who fails to cooperate with obtaining the Divorce shall pay all
the costs and legal fees of the party who is seeking the divorce.
16.
BREACH: If either party breaches any provisions of this Agreement, the other party
should have the right, at his or her election, to sue for damages for such breach or seek such other
remedies or relief as may be available to him or her, and the party breaching this contract will be
responsible for payment of legal fees and costs incurred by the other in enforcing their rights
under this Agreement.
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17.
ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the
request of the other, execute, acknowledge and deliver to the other party any and all further
instruments that may be reasonably required to give full force and effect to the provisions of this
Agreement.
18.
VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect
have been fully explained to the parties by their respective counsel, and each party
acknowledges that the Agreement is fair and equitable, and that it is being entered into
voluntarily, and that it is not the result of any duress or undue influence. The provisions of this
Agreement are fully understood by,jJoth parties and each party acknowledges that the Agreement
is fair and equitable, that it is being entered into voluntarily, and that it is not the result of any
duress or undue influence.
19.
ENTIRE AGREEMENT: This Agreement contains the entire understanding of the
parties and there are no representations, warranties, covenants or undertakings other than those
expressly set forth herein.
20.
APPLICABLE LAW: This Agreement shall be construed under the Laws of the
C0mn1onwea1th of Pennsylvania.
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21.
PRIOR AGREEMENTS: It is understood and agreed that any and all property
settlement agreements which mayor have been executed prior to the date and time of this
Agreement are null and void and of no effect.
22.
PAYMENT OF COSTS AND LEGAL FEES: The parties agree to pay for their own
costs and legal fees required to obtain and complete the divorce.
23.
WAIVER OF CLAIMS AGAINST ESTATES: Except as herein otherwise provided,
each party may dispose of his or her property in any way, and each party hereby waives and
relinquishes any and all rights he or she may now have or hereafter acquire, under the present or
future laws of any jurisdiction, to share in the property or the estate of the other as a result of the
marital relationship, including without limitation, dower, courtesy, statutory allowance, widow's
allowance, right to take in intestacy, right to take against the Will of the other, and right to act as
administrator or executor of the other's estate, and each will, at the request of the other, execute,
acknowledge and deliver any and all instruments which may be necessary or advisable to carry
into effect this mutual waiver and relinquishment of all such interests, rights and claims.
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IN WITNESS WHEREOF, the parties hereunto have set their hands and seals the day
and year first above written.
~ffi. RdJ~UY\
LISA M. ROBINSON
(SEAL)
cu if. ~ ~Pl}' _
DALE L. ROBINSON
(SEAL)
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COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF CUMBERLAND
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PERSONALLY APPEARED BEFORE ME, this L day of May, 2002, a Notary
Public, in and for the Commonwealth of Pennsylvania and County of Cumberland, LISA M.
ROBINSON, known to me (or satisfactorily proven) to be the person whose name is subscribed
to the within Marriage Settlement Agreement, and acknowledges that she executed the same for
the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
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COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF CUMBERLAND
PERSONALLY APPEARED BEFORE ME, this Jl;~"day of May, 2002, a Notary
Public, in and for the Commonwealth of Pennsylvania and County of Cumberland, DALE L.
ROBINSON, known to me (or satisfactorily proven) to be the person whose name is subscribed
to the within Marriage Settlement Agreement, and acknowledges that he executed the same for
the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
Notarial Seal
Martha L. Noel, Notary Public
Carlisle Borc. Cumberland County
My Commission Expires Sept. 18, 2003
Member Pennsylvania Association of Notaries
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DALE L. ROBINSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000-8434 CIVIL TERM
LISA M. ROBINSON,
Defendant
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the court for entry of a divorce decree:
I. Ground for Divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code.
2. Date and manner of service of complaint: A certified copy of the Complaint in Divorce was served upon
the defendant, Lisa M. Robinson, on December 8, 2000, by certified, restricted delivety mai~ addressed to her at II
Green Meadow Drive, Carlisle, Pennsylvania 17013, with Return Receipt Number 7099340000184997 1643.
3. Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce
Code: by plaintiff: May 2, 2002; by defendant: May 8, 2002 .
(b)(I) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code:
(b)(2) Date of filing and service of the plaintiff's affidavit upon the defendant:
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 Section 3301(c) Divorce was filed with the
Prothonotary: May 10,2002.
Date defendant's Waiver of Notice in Sectio
Prothonotary: May 10, 2002.
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DALE L. ROBINSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CML ACTlON,- LAW
LISA M. ROBINSON,
Defendant
: oo-t<t3<(-
CIVIL TERM
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 wamed that if you fail to do so, the case
may proceed without you and a decree in 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 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, Cumberland County Courthouse, Carlisle, Pennsylvania 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION 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 County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
717-249-3166
1-800-990-9108
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AMERICANS WITH DISABILITIES
ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the court,
please contact our office. All arrangements must be made at least 72 hours prior to any hearing
or business before the court. Yon must attend the scheduled conference or hearing.
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DALE L. ROBINSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
: ()tJ- S'/?J'I -
CIVIL TERM
LISA M. ROBINSON,
Defendant
IN DIVORCE
COMPLAINT ~ DIVORCE PURSUANT IQ SECTION 3301(c)
OF THE DIVORCE CODE
NOW comes the plaintiff, Dale L. Robinson, by his attorney, Marcus A. McKnight, III,
Esquire, and files this Complaint in Divorce against the defendant, Lisa M. Robinson, representing as
follows:
1. The plaintiff is Dale L. Robinson, an adult individual residing at 11 Green Meadows Drive,
Carlisle, Cumberland County, Pennsylvania 17013.
2. The defendant is Lisa M. Robinson, an adult individual residing at 11 Green Meadow Drive,
Carlisle, Cumberland County, Pennsylvania 17013.
3. The plaintiff has been a resident 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 November 20, 1993, in Carlisle,
Pennsylvania.
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5. There have been no prior actions of divorce or for annulment between the parties.
6. Pursuant to the Divorce Code, Section 330l(c), the plaintiff avers as the grounds upon which
this action is based that the marriage between the parties is irretrievably broken.
7. The plaintiff avers that he has been advised of the availability of counseling and that said
party has the right to request that the court require the parties to participate in counseling.
WHEREFORE, the plaintiff demands judgment dissolving the marriage between the two
parties.
Respectfully submitted,
By:
M cusA.Mc .g,
Attorney for Plaintif
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
Supreme Court LD. No. 25476
Date: December 4, 2000, 2000
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VERIFICATION
The foregoing Complaint in Divorce is based upon information which has been gathered
by counsel and myself in the preparation of this action. I have read the statements made in this
document and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section
4904, relating to unswom falsification to authorities.
Q..L-cX ~
DALE L. ROBINSON
Date December 4, 2000
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DALE L. ROBINSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
:
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CIVIL TERM
LISA M. ROBINSON,
Defendant
IN DIVORCE
PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT
The plaintiff, being du1y swom 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. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: December 4, 2000
Q~ ~ t~~
DALE L. ROBINSON
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DALE L. ROBINSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CML ACTION - LAW
2000-8434 CIVIL TERM
LISA M. ROBINSON,
Defendant
IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 330l(c) of the Divorce Code was filed on
December 5, 2000.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of the filing of the complaint.
3. I consent to the entry of a final decree in divorce.
4. 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.
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. C. S. Section 4904 relating to
unsworn falsification to authorities.
M ,,1\.1. 2 02
Date: ay!!. , 0
Q~!t~
DALE L. ROBINSON
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DALE L. ROBINSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000-8434 CIVIL TERM
LISA M. ROBINSON,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
I. 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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
~
Date: May a , 2002
QP~~
DALE L. ROBINSON
Plaintiff
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DALE L. ROBINSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000-8434 CML TERM
LISA M. ROBINSON,
Defendant
IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
December 5, 2000.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of the filing of the complaint.
3. I consent to the entry of a final decree in divorce.
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 made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to
unsworn falsification to authorities.
Date: May 0 ,2002
~l&l. m _ 1Zo1&.nc; dV\
LISA M. ROBINSON
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DALE L. ROBINSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000-8434 CIVIL TERM
LISA M. ROBINSON,
Defendant
IN DIVORCE
DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT
The defendant, being duly swom 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. C.S. Section 4904 relating to
unswom falsification to authorities.
Date: May B ,2002
.
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LISA M. ROBINSON
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DALE L. ROBINSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CML ACTION - LAW
2000-8434 CML TERM
LISA M. ROBINSON,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 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 ifI 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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relaling to
unsworn falsification to authorities.
Date: May ~, 2002
~ift Rnb.wli~
, LISA M. ROBINSON
Defendant
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DALE L. ROBINSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000-8434 CIVIL TERM
LISA M. ROBINSON,
Defendant
IN DIVORCE
AFFIDAVIT OF SERVICE OF COMPLAINT
PURSUANT TO PA. R.C.P. RULE NO. 1920.4 (a)(1)(i)
COMMONWEALTH OF PENNSYLVANIA
: SS:
COUNTY OF CUMBERLAND
NOW, Marcus A. McKnight, III, Esquire, being duly swom according to law, does
depose and state:
1. That he is a competent adult and attomey for the plaintiff in the captioned action in
divorce.
2. That a certified copy of the Complaint in Divorce was served upon the defendant, Lisa
M. Robinson, on December 8, 2000, by certified, restricted delivery mail, addressed to her at II
Green Meadow Drive, Carlisle, Pennsylvania 17013, with Return Receipt Number 7099 3400
001849971643.
3. That the said receipt for certified mail is signed and attached hereto and made a part
hereof.
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 Pa. C. S. sec~04;J'1ating to
unsworn falsification to authorities. C #;: ~4 ~
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US A. McKNIGH ESQUIRE
Attorney for Plaintiff
Date: May \0"" , 2002
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Postage $
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Return Receipt Fee
(Endorsement Required)
Restricted Delivery Fee
(Endorsement Required)
C Total Postage & Fees $
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::r 13fl/;jpient's Nqme_rt'lease Print ClealM.Jto be completed by mailer)
ITI l'U; LISA M ROBINSUN
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1. Article Addressed to:
dedyery address different from item 1?
YESl, enter delivery address below:
M8 LISA K ROBINSON,
11 GREEN KEADOW DRIvE\.
CARLISLE PA 17013 '. "
3. Seroice Type
1m Certified Mail
o Registered
o Agent
o Addressee
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IB Return Receipt for Merchandise
4. Restri~ed Delivery? (Extra Fee)
2. Article Number (Copy from service label)
7~9 3400P018,4997164~
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D~m~c' Ret~rn ReCeipt '
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PS Form 381 i, July 1999
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102595-99-M.1789
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Andrew C. Sheely, Esquire
127 S. Market Street
P.O. Box 95
Mechanicsburg, PA 17055
PA ID NO. 62469
717-697-7050 (Phone)
717-697-7065 (Fax)
DALE L. ROBINSON,
v.
LISA M. ROBINSON,
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Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
00-8434
CIVIL ACTION - LAW
Defendant
IN DIVORCE
TO: CURTIS R. LONG, PROTHONOTARY
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
PRAECIPE FOR ENTRY OF APPEARANCE
Kindly enter my appearance on behalf of Defendant, Lisa M.
Robinson, in the above-captioned matter.
December I'> , 2000
BY:~
ANDREW C. SHEELY, SQUIRE
Pa. LD. No. 62
127 S. Market Street
P.O. Box 95
Mechanicsburg, PA 17055
(717) 697-7050
Attorney for Plaintiff
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CERTIFICATE OF SERVICE
I, Andrew C. Sheely, Esquire, hereby certify that I am this
day serving the foregoing praecipe for Entry of Appearance upon
the following named individual this day by depositing same in the
United States Mail, First Class, postage prepaid, at
Mechanicsburg, pennsylvania, addressed as follows:
MARCUS A. MCKNIGHT
WEST POMFRET PROFESSIONAL BUILDING
60 WEST POMFRET STREET
CARLISLE, PA 17013-3222
Date: December \'3
~~~.
, 2000
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DALE L. ROBINSON,
Plaintiff/Respondent
v.
LISA M. ROBINSON,
Defendant/petitioner
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
00 - 8434
ORDER OF COURT
AND NOW, this
7~
day of
F~
2001, the attached Stipulation and Agreement is hereby incorporat-
ed as an Order of Court.
Marcus A. McKnight, III, Esquire
Attorney for Plaintiff
Andrew C. Sheely, Esquire
~ttorney for Defendant
BY THE
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DALE L. ROBINSON,
plaintiff/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
LISA M. ROBINSON,
Defendant/petitioner
00 - 8434
CUSTODY STIPULATION AND AGREEMENT
THIS AGREEMENT AND STIPULATION entered into this
~1/rrr
day
of January, 2001, by and between Dale L. Robinson, plaintiff,
(hereinafter referred to as "Father") and Lisa M. Robinson, Defen-
dant, (hereinafter referred to as "Mother").
WHEREAS, the parties are the natural parents of paige Marie
Robinson, d.o.b. March 14, 1996., (hereinafter referred to as the
"child"); and
WHEREAS, Mother is the natural motper of the aforenamed child
and Father is the natural father of the aforenamed child; and
WHEREAS, the parties live in separate residences and are
married, but currently separated; and
WHEREAS, the parties wish to enter into an Agreement and
Stipulation relative to custody and partial custody of the child;
and
NOW, THEREFORE, in consideration of the mutual covenants,
promises and agreements as hereinafter set forth, the parties
agree as follows:
(1) Mother and Father shall have shared legal custody of the
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child, meaning that both parents shall have an equal right, to
be exercised jointly with the other parent, to make all major non-
emergency decisions affecting the child's well being including,
but not limited to all decisions regarding her health, education
and religion. Pursuant to the terms of this Agreement, each
parent shall be entitled to all records and information pertaining
to the child including, but not limited to, school and medical
records and information, as available. To the extent one parent
has possession or control of such records, that parent shall be
required to share the same or copies thereof with the other parent
within such reasonable time as to make the records and information
of reasonable use to the other parent. If the child requires a
major medical procedure or medical appointment for a significant
illness, the Mother shall notify the Father fourteen (14) days in
advance, or as soon as the Father himself receives notice.
(2) Father and Mother agree that Mother shall have primary
physical custody of the child in accordance with the terms of this
Agreement.
(3) Mother and Father agree that Father shall have periods
of partial physical custody on the following basis:
(a) On every other weekend, commencing on Friday at 6:00
p.m. and continuing through Sunday afternoon at 5:00 p.m.;
and
(b) Every Monday evening after Mother's weekend and
2
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every Thursday evening before Mother's weekend, from 3:15
p.m. through 7:00 p.m. on each evening; and
(e) In the event Father or Mother are unable to provide
custody during his or her respective periods, then Father or
Mother shall notify the other party of the unavailability and
provide each other with the opportunity for custody during
such period of unavailability.
(4) Christmas Holiday. The Christmas Holiday shall consist
of two (2) periods. Period (a) shall commence at 12:00 p.m. on
December 24 and end at 12:00 p.m. on December 25. Period (b)
shall commence at 12:00 p.m on December 25 and shall end at 12:00
p.m. on December 26. Mother shall have period (a) in odd years and
period (b) in even years. Father shall have period (b) in odd
years and period (a) in even years.
(5) Easter Sunday.
Easter Sunday shall consist of two
(2) periods. Period (a) shall commence at 9:00 a.m. on Easter
Sunday end at 2:00 p.m on Easter Sunday. Period (b) shall com-
mence at 2:00 p.m on Easter Sunday and shall end at 8:00 p.m. on
Easter Sunday. Mother shall have period (a) in odd years and
Father shall have period (a) in even years. Mother shall have
period (b) in even years and Father shall have period (b) in odd
years.
(5) Thanksaivina Day. Thanksgiving Day shall consist of two
(2) periods. Period (a) shall commence at 9:00 a.m. on Thanksgiv-
ing Day and end at 2:00 p.m on Thanksgiving Day. Period (b) shall
commence at 2:00 p.m on Thanksgiving Day and shall end at 8:00
3
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p.m. on Thanksgiving Day. Mother shall have period (a) in odd
years and Father shall have period (a) in even years. Mother shall
have period (b) in even years and Father shall have period (b) in
odd years.
(6) New Years Day. Memorial Day, Fourth of July and Labor
Day. Mother and Father shall alternate Memorial Day, Fourth of
July and Labor Day. Father shall have Memorial Day commencing in
200!.
(7) vacation Mother and Father agree that Father shall have
a period of three non-consecutive weeks of custody with the child
during the year, provided that Father shall not exercise any seven
(7) day period between December 24 through January 1. The period
shall not exceed seven (7) days. In the event Father desires
vacation custody with the child, he shall provide Mother with
notice of such intention within thirty (30) days of the requested
time period. If Father does not provide such notice within thirty
(30) days of such period, Mother, at her option, may refuse to
grant Father custody in accordance with this paragraph. Father
shall remain responsible for all expenses incurred by child during
any vacation and Father shall provide Mother with all telephone
numbers where the child can be reached during such period; and
(8) Mother's Day and Father's Day In addition to the dates
and times set forth above, the child shall always spend Mother's
4
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Day with Mother and Father's Day with Father. Mother and Father
agree that custody with child shall commence at 9:00 a.m. and end
at 7:00 p.m. on such day. Likewise, the child shall always spend
the child's birthday with the Mother during odd numbered years and
with Father during even numbered years during the same time peri-
ods contained in the sub-paragraph; and
(9) And any other times as the parties may agree.
(10) Father provide transportation and pick-ups and drop-offs
shall occur at the residence of Mother.
(11) The parties will keep each other immediately advised to
any emergencies concerning the child and shall further take any
necessary steps to insure that the health and well being of the
child is always protected. The parties shall provide each other
with all home and work telephone numbers, as well as current
addresses for the residence of the child. Both parties further
agree to allow each other to speak with the child at any and all
reasonable times as set forth below.
(12) Neither parent shall do anything which may estrange the
child from the other party, or injure the opinion of the child as
to the other party, or which may hamper the free and natural
development of the child's love or affection for the other party.
(13) Mother and Father agree that each shall communicate to
each other through one-another whenever possible in accordance
5
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with the terms set forth in this Agreement and that they shall not
use child as a liaison to communicate with each other as to oral
modifications of this Agreement and Stipulation.
(14) Any modification or waiver of any of the provisions of
this shall be effective only if made in writing and only if ex-
ecuted with the same formality as this Agreement and Stipulation.
In the event any Court deems this Agreement and Stipulation une-
nforceable due to changed or unforseen circumstances, such deci-
sion shall have no effect on the remaining portions of the Agree-
ment and Stipulation.
(15) Neither party shall use or be in possession of any
illegal substances during any period of custody contact and nei-
ther party shall use or consume excessive amounts of alcohol
during any period of custody with the child. Further, both par-
ties shall ensure that, during his or her period of custody, that
the child is not exposed to third parties who may be using, sell-
ing or possessing illegal drugs or consuming excessive alcohol.
(16) The parties agree that any Court of competent jurisdic-
tion may enforce or modify relevant portions of this Agreement and
Stipulation. The parties further acknowledge that either party may
petition any Court with appropriate jurisdiction over the child
should circumstances change and either party desire modification
of this Agreement and Stipulation. This Agreement and Stipulation
6
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shall be construed under the laws of the Commonwealth of Pennsyl-
vania. Enforcement of this Agreement and Stipulation for any
material breach shall be governed by 23 Pa. C.S.A. Section 3105,
as well as any legal or equitable action authorized by law.
(17) Both parties agree that an order of Court shall be
entered which incorporates the terms of this Stipulation and
Agreement. In the absence of mutual consent, the terms of this
Stipulation and Agreement shall control.
IN WITNESS WHEREOF, the parties have hereunto set their hands
and seals the day and year first above written.
QAi ~~
Dale L. Robinson
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i a M. Robinson
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