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LARRY R. KENNEDY and
PATRICIA L. KENNEDY,
Plaintiffs
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
vs.
CIVIL ACTION - LAW
NO. 01- /$'// CIVIL TERM
CUSTODY
EDWARD R. KENNEDY,
Defendant
PETITION
AND NOW, comes Larry R. Kennedy and Patricia 1. Kennedy, Plaintiff herein, by and through
his attorneys, Frey & Tiley, and makes the following statement:
1. Plaintiffs are Larry R. Kennedy and Patricia 1. Kennedy of the Borough of Carlisle, County
of Cumberland, Commonwealth Pennsylvania (mailing address: 247 "P' Street; Carlisle, Pennsylvania)
2. Defendant is Edward R. Kennedy of 2071 Ritner Highway, Carlisle, Cumberland County,
Pennsylvania.
3. Plaintiff and Defendant are the natural parents of Alyssa Lorraine Kennedy, born December
26, 1989, currently residing at 247 "F" Street, Carlisle, Pennsylvania.
4. Plaintiff and Defendant have entered into an agreement concerning the custody and
visitation of the aforesaid child, which agreement is attached hereto as Exhibit" A".
5. Plaintiff now desires to have this agreement entered as an Order of Court as it is believed
that the terms of the agreement will best serve the interests of the aforesaid child.
WHEREFORE, Plaintiff respectfully requests that the Court grant shared legal custody to the
parties herein and primary physical custody to Plaintiff with visitation to Defendant as agreed to by the
parties in Exhibit "A".
Respectfully submitted,
Frey & Tiley
d.
by:
R bert G. Frey
Attorney for Plaintiffs
5 South Hanover Street
Carlisle, Pennsylvania 17013
(717) 243-5838
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CUSTODY AGREEMENT
ENTERED INTO this ,-~h day of ~b
,2001
BETWEEN, Edward R. Kennedy of 2071 Ritner Highway, Carlisle, Cumberland
County, Pennsylvania, hereinafter referred to as "Father",
AND Larry R. Kennedy and Patricia L. Kennedy of the Borough of Carlisle,
County of Cumberland, Commonwealth Pennsylvania (mailing address: 247 "P' Street, Carlisle,
Pennsylvania), hereinafter referred to as "Grandparents",
WHEREAS, Father is sole surviving the parent of Alyssa Lorraine Kennedy, born
December 26, 1989, a minor, hereinafter referred to as "the child";
WHEREAS, the mother of the child, Tina Kennedy, died January 26, 2001;
WHEREAS, Grandparents have agreed with Father to assume the responsibilities of caring
for and raising the child;
WHEREAS, Father and Grandparents acknowledge that the child is now living with
Grandparents, has been living with Grandparents since December 18, 200t? and has been attending
school in Grandparents district since DccelRegr 1 g, 2001;
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WHEREAS, Father and Grandparents believe that the best interests of the child is served
by the present custodial arrangement;
WHEREAS, Father and Grandparents believe that it is in the best interests of the child to
reach an agreement as to the relative custody, partial custody, and visitation of the child;
WHEREAS, Father and Grandparents desire to have said agreement entered as an Order of
Court having jurisdiction over the child
NOW THEREFORE, in consideration of the mutual covenants, promises, and agreements
as hereinafter set forth, the parties agree as follows:
I. Grandparents shall have joint legal custody of the child.
2. Grandparents shall have primary physical custody of the child.
3. Father shall have reasonable periods of partial or temporary custody with the child,
as reasonably agreed to by the parties.
4. Grandparents and Father agree that they will work to the best interests of child.
5. Grandparents and Father agree that they will each notify the other immediately in
cases of medical emergencies that occur while the child is in their custody.
6. Any modification or waiver of any of the provisions of this Agreement shall be
effective only if made in writing executed with the same formality as this Agreement.
7. Neither party 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
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development ofthe child's love or affection for the other party.
9. Grandparents and Father each agree that in making this Agreement, there has been
no fraud, concealment, overreaching, coercion, or other unfair dealing on the part of the other.
10. It is understood by Grandparents and Father that this Agreement shall be submitted
for incorporation into an Order of Court and may be modified by the Court of Common Pleas of
Cumberland County or any other Court having proper jurisdiction based on the laws in effect in the
jurisdiction.
INTENDING to be legally bound, witness our hand and seal the day and year first above
written.
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Patricia L. Kennedy .
(SEAL)
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I verify that the statements made herein are true and correct imd understand that false
statements herein are made subject to the penalties of 18 Pa. C. S. A. ~ 4904 relating to unsworn
falsification to authorities.
Dated: F~(.,rv cJ') S,200l
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Patricia L. ennedy
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MAR 19 2001tfJ
LARRY R. KENNEDY and
PATRICIA L. KENNEDY,
Plaintiffs
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. Ol-I.s-/J CIVIL TERM
CUSTODY
EDWARD R. KENNEDY,
Defendant
ORDER OF COURT
AND NOW, this 2...'J day of ~,2001, upon consideration of the within Petition and
upon Agreement of the parties attached to the within Petition as Exhibit "A", it is ordered and decreed that
legal custody and primary custody of Alyssa Lorraine Kennedy and be granted to Larry R. Kennedy and
Patricia L. Kennedy, with partial physical custody to Edward R. Kennedy, as more specifically set forth in
the Agreement of the parties.
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