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CRISTY L. PAUL,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO.61- 14/,l,..
CIVIL TERM
:
JEFFREY BURRELL,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
ORDER OF COURT
AND NOW, this
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stipulation of the parties, it is hereby Ordered and Decreed:
1. Plaintiff, Cristy L. Paul, and Defendant, JefiTey Burrell, shall have shared legal custody
ofJason Burrell, born November 17, 1984. Each parent shall have an equal right, to he exercised
jointly with the other parent, to make all major non-emergency decisions affecting the child's general
well-being including, but not limited to, all decisions affecting the child's health, education, and
religion. Pursuant to the terms of this paragraph, 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.
2. The Plaintiff shall have primary physical custody of the child, subject to the
Defendant's rights of partial physical custody, during the school months, as follows:
A. Defendant shall be entitled to visitation every other weekend, from
Friday, after Defendant's work, until Sunday at 6:00 p.m. When a national holiday
is observed on a Monday, subsequent to Defendant's weekend period of custody, and
school is not in session, Defendant shall retain custody of the minor child until 6:00
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p.m. on the day of the holiday; and
B. Any additional periods of physical custody which the parties may agree
upon.
3. During the non-school months, Defendant shall exercise periods of partial physical
custody, as follows:
A. Defendant shall be entitled to visitation every other weekend, from
Friday, at the end of Defendant's work schedule, until Sunday at 6:00 p.m. When a
national holiday is observed on aMonday, subsequent to Defendant's weekend period
of custody, and school is not in session, Defendant shall retain custody of the minor
child until 6:00 p.m. on the day of the holiday;
B. Every Tuesday evening, overnight, from the end of Defendant's work
schedule, until Wednesday morning before work;
C. Every Wednesday evening, overnight, from the end of Defendant's work
schedule, until Thursday morning before work;
D. One (1) full week of uninterrupted visitation during the summer
lIl()nths, with the exact details to be determined by the parties; and
E. Any additional periods of physical custody which the parties may agree
upon.
4. Holidays shall be shared between the parties upon the following schedule:
A. Defendant shall be'entitled to visitation on Father's Day and Plaintiff'
shall be entitled to visitation on Mother's Day, with the exact details to be determined
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by the parties.
B. The parties shall share custody of the child on the Christmas holiday
as follows:
1. Schedule A: From 6:00 p.m., or
earlier if agreed upon between the parties, on
Christmas Eve until 12:00p.m. on Christmas Day; and
2. Schedule B: From 12:00 p.m. on
Christmas Day until 6:00 p.m., or later if agreed upon
between the parties, on December 26th.
Plaintiff shall exercise her period of custody over the child in
accordance with the Schedule A provisions in all odd numbered years
and with the Schedule B provisions in all even numbered years.
Defendant shall exercise his period of custody over the child in
accordance with the Schedule A provisions in all even numbered years
and with the Schedule B provisions in all odd numbered years.
C. The following major holidays shall be equally divided between the
parties, with the exact details of such to be determined by the parties: New Year's
Day, Easter, Memorial Day, July Fourth, Labor Day, and Thanksgiving Day,
5. The parties shall keep each other informed of their respective current addresses and
telephone numbers.
6. Each parent shal1 be entitled to reasonable telephone contact with the child while he
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is in the custody of the other parent The child should be encouraged to telephone the non-custodial
parent at reasonable intervals.
7, Each parent shall encourage the participation of the child in extracurricular activities
and the child's part-time employment through Burger King. Each party agrees to remain flexible and
understanding, during any contlicts which may arise between the child's employment schedule and
the stated custody schedule and times set forth in this stipulation. Transportation to and from
extracurricular activities and employment, shall be the responsibility of the parent exercising physical
custody. The parties agree during the months of September through and including December,
Plaintiff shall be responsible for providing transportation for the child on Sundays.
8. Both parties shall encourage the child to love and respect the other and shall not make,
nor allow others to make, in the presence of the child, derogatory comments about the other parent.
Further, each parent shall encourage the child to have significant contact with the other parent, and
shall make certain that the child is ready on time for the transfer of physical custody of the child from
one parent to the other.
9. During any period of custody or visitation the parties to this Order shall not possess
or use any controlled substance, neither shall they consume alcoholic beverages to the point of
intoxication. The parties shall likewise assure, to the extent possible, that other household members
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CRISTY L. PAUL,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
; NO. 0/- I'f(gl,
CIVIL TERM
JEFFREY BURRELL,
Defendant
: CIVIL ACTION - LAW
; IN CUSTODY
STIPULATION FOR CUSTODY
WHEREAS, the Plaintiff and Defendant are the parents of one minor child, to wit: Jason
Burrell, born November 17, 1984;
WHEREAS, the Plaintiff and Defendant, after careful consideration and the opportunity for
the advice and assistance of counsel, have reached an agreement to provide for the custody of this
child without the need to litigate the matter before this Honorable Court and asks the Court to adopt
this agreement as its Order;
WHEREAS, it is the belief of the Plaintiff and Defendant that the agreement reached herein
provides for the best interest of this child;
NOW THEREFORE, intending to be legally bound, the parties agree as follows:
1. Plaintiff, Cristy L. Pau~ and Defendant, Jeffrey Burrell, shall have shared legal custody
of Jason Burrell, born November 17, 1984. Each parent shal1 have an equal right, to be exercised
jointly with the other parent, to make all major non-emergency decisions affecting the child's general
we1l-being including, but not limited to, all decisions affecting the child's health, education, and
religion. Pursuant to the terms of this paragraph, each parent shall be entitled to all records and
information pertaining to the child, including, but not limited to, school and medical records and
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information.
2. The Plaintiff shall have primary physical custody of the child, subject to the
Defendant's rights of partial physical custody, during the school months, as follows:
A. Defendant shall be entitled to visitation every other weekend, from
Friday, after Defendant's work, until Sunday at 6:00 p.m. When a national holiday
is observed on a Monday, subsequent to Defendant's weekend period of custody, and
school is not in session, Defendant shall retain custody of the minor child until 6: 00
p.m. on the day of the holiday; and
B. Any additional periods of physical custody which the parties may agree
upon,
3. During the non-school months, Defendant shall exercise periods of partial physical
custody, as follows:
A. Defendant shall be entitled to visitation every other weekend, from
Friday, at the end of Defendant's work schedule, until Sunday at 6:00 p.m. When a
national holiday is observed on a Monday, subsequent to Defendant's weekend period
of custody, and school is not in session, Defendant shall retain custody of the minor
child until 6:00 p.m. on the day of the holiday;
B. Every Tuesday evening, overnight, from the end of Defendant's work
schedule, until Wednesday morning before work;
C, Every Wednesday evening, overnight, from the end of Defendant's work
schedule, until Thursday morning before work;
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D. One (1) full week of uninterrupted visitation during the summer
months, with the exact details to be determined by the parties; and
E. Any additional periods of physical custody which the parties may agree
upon.
4. Holidays shall be shared between the parties upon the following schedule:
A. Defendant shall be entitled to visitation on Father's Day and Plaintiff
shall be entitled to visitation on Mother's Day, with the exact details to be determined
by the parties.
B. The parties shall share custody of the child on the Christmas holiday
as follows:
L Schedule A: From 6:00 p.m. on
Christmas Eve until 12:00 p.m. on Christmas Day; and
2. Schedule B: From 12:00 p.m. on
Christmas Day until 6:00 p.rn, on December 26th.
Plaintiff shall exercise her period of custody over the child in
accordance with the Schedule A provisions in all odd numbered years
and with the Schedule B provisions in all even numbered years.
Defendant shall exercise his period of custody over the child in
accordance with the Schedule A provisions in all even numbered years
and with the Schedule B provisions in all odd numbered years.
C. The following major holidays shall be equally divided between the
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parties, with the exact details of such to be determined by the parties: New Year's
Day, Easter, Memorial Day, July Fourth, Labor Day, and Thanksgiving Day.
5. The parties shall keep each other informed of their respective current addresses and
telephone numbers.
6. Each parent shall be entitled to reasonable telephone contact with the child while he
is in the custody of the other parent. The child should be encouraged to telephone the non-custodial
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parent at reasonable intervals.
7. Each parent shall encourage the participation of the child in extracurricular activities
and the child's part-time employment through Burger King. Each party agrees to remain flexible and
understanding, during any conflicts which may arise between the child's employment schedule and
the stated custody schedule and times set forth in this stipulation. Transportation to and from
extracurricular activities and employment, shall be the responsibility of the parent exercising physical
custody. The parties agree during the months of September through and including December,
Plaintiff shall be responsible for providing transportation for the child on Sundays.
8. Both parties shall encourage the child to love and respect the other and shall not make,
nor allow others to make, in the presence of the child, derogatory comments about the other parent.
Further, each parent shall encourage the child to have significant contact with the other parent, and
shall make certain that the child is ready on time for the transfer of physical custody of the child from
one parent to the other.
9. During any period of custody or visitation the parties to this Order shall not possess
or use any controlled substance, neither shall they consume alcoholic beverages to the point of
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intoxication. The parties shall likewise assure, to the extent possible, that other household members
and/or house guests comply with this prohibition.
10. Plaintiffisrepresented by Cara A. Boyanowski, Esquire. Defendant isnot represented
by counsel. All parties have been informed of the purpose of this Agreement and its legal effects and
consequences,
11. Each of the parties has carefully read and fully considered this Stipulation and all of
the statements, terms, conditions, and provisions thereof prior to signing below.
IN WITNESS WHEREOF, intending to be legally bound hereby, the parties hereto have
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set their hands and seals on this q J.h day of ---.hI QA ch , 269Q..
WITNESS:
(1p~~
Counsel for Plaintiff
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