Loading...
HomeMy WebLinkAbout07-1470TAMMIE L. PETERS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW ADAM S. PETERS, No. o l- I Y'70 CIVIL Defendant IN CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is Tammie L. Peters, residing at 331 Greenspring Road, Newville, Cumberland County, Pennsylvania 17241. 2. The defendant is Adam S. Peters, residing at 5312 Oxford Circle, Apt. 6, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff seeks cu: Name Tyler D. Peters Alexus N. Peters ;tody of the following child: Present Residence DOB Age 331 Greenspring Road 5/9/1999 7 Newville, PA 17241 331 Greenspring Road 1/712003 4 Newville, PA 17241 The child Tyler was born out of wedlock and the daughter Alexus was born in wedlock. The children are presently in the custody of Mother, residing at 331 Greenspring Road, Newville, Cumberland County, Pennsylvania 17241. During the past five years, the children have resided with the following persons and at the following addresses: List All Persons List All Addresses Dates Adam S. Peters & 331 Greenspring Road 8/2001-6/2005 Tammie L. Peters Newville, PA 17241 Tammie L. Peters 448 Shed Road 6/2005-7/2006 Newville, PA 17241 Tammie L. Peters & 331 Greenspring Road 7/2006-present Dennis Crutcher Newville, PA 17241 4. 5. 6. 7. 8. The mother of the children is Tammie L. Peters, residing at 331 Greenspring Road, Newville, Cumberland County, Pennsylvania. 17241. She is not married. The father of the children is Adam S. Peters, residing at 5312 Oxford Circle, Apt. 6, Mechanicsburg, Cumberland County, Pennsylvania 17055. He is not married. The relationship of plaintiff to the children is that of Mother. The plaintiff currently resides with the following persons. Name Dennis Crutcher Relationship Boyfriend The relationship of defendant to the child is that of Father. The defendant currently resides with the following persons. Name Sheena Hollingsworth Ethan Hollingsworth Maddy Hollingsworth Relationship Girlfriend Girlfriends Son Girlfriends Daughter Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child and claims to have custody or visitation rights with respect to the child. The best interest and permanent welfare of the child will be served by granting the relief request because: A Court Order of custody and structured visitation is desired so that the Plaintiffand the child may plan their schedules accordingly, and so that misunderstandings and unmet expectations regarding custody and visitation can be avoided, and also so that the child is not used in a manipulative fashion. Plaintiff desires to maintain the family household which has been established, and the continued stability of the household is in the best interest of the child. A Court Ordered determination of custody is required to avoid continuing conflict between the parties regarding responsibility for custody and support. WHEREFORE, Plaintiffrequests this Court grant Plaintiffprima y physical custody subject to partial custody by the Defendant. Respectfully submitted, Rominger & Asnociates Date: March 12, 2007 2.1 =Romiingger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court I.D. # 81924 Attorney for Plaintiff TAlb M E L. PETERS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW ADAM S. PETERS, : No. CIVIL Defendant IN CUSTODY VERIFICATION 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 Pa. Cons. Stat. § 4904 relating to unworn falsification to authorities. 4 ammie VPPs , P laintiff TAM]MIE L. PETERS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW ADAM S. PETERS, No. CIVIL Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, attorney for plaintiff do hereby certify that I this day mailed a copy of the within upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Adam S. Peters 5312 Oxford Circle, Apt. 6 Mechanicsburg, Pennsylvania 17055 Date: March 12, 2007 Respectfully submitted, Rominger & Associates ZEominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court I.D. # 81924 Attorney for Plaintiff TAMAIE L. PETERS, Plaintiff V. ADAM S. PETERS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. CIVIL IN CUSTODY STIPULATION AGREEMENT AS TO CUSTODY The plaintiff, Tammie L. Peters, hereinafter referenced as "Mother," and Defendant, Adam S. Peters, hereinafter referenced as "Father," hereby agree to the entry of the following terms in a Court Order defining custody and partial custody rights and responsibilities in relation to the parties' minor children, Tyler D. Peters, born 5/9/1999, and Alexus N. Peters, born 1/7/2003, hereinafter referenced as "Children": The parties hereto agree that the best interest and continuing welfare of the Children would be best served with the custody arrangement as follows: (a) Mother and Father will share legal custody of Children as defined in 23 Pa. C.S.A. §5302. All decisions affecting the Children's growth and development, including but not limited to medical treatment, education, and religious training, are major decisions which Mother and Father shall make jointly after discussion and consultation with each other. (b) As provided 23 Pa. C.S.A. §5309(a), each parent shall have full and complete access to the Children's mental, dental, religious and school records. This includes the names, addresses and telephone numbers of all medical and other providers. (c) Mother shall have primary physical custody of the Children. (d) Father shall have periods of partial custody every other weekend from Friday evening starting at 4: 30 p.m. until Sunday evening at 7:30 p.m., beginning the weekend of Friday, March 16, 2007. (e) The parties shall share holidays by mutual agreement. (f) Visitation may be at such other times as the parties mutually agree. 2. Each parry shall have reasonable telephone and e-mail access to the Children while the Children are in the custody control of the parent. 3. The parties shall keep each other advised immediately relative to any emergencies concerning the Children and shall further take any necessary steps to ensure that the health, welfare and well being of the Children are protected. The parties shall do nothing that may estrange the Children from the other party or hinder the natural development of the Children's love or affection for the other parry. 4. Each party shall not make any disparaging remarks or allow others to make any disparaging remarks concerning the Children's parents in front of the Children. 5. Any modification or waiver of any of the provisions of the agreement of the parties shall be effective only if made in writing and only if executed with the same formality of the agreement of the parties. 6. 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. 7. Both parties agree that the terms of this agreement have been fully explained to them by their respective counsel or that both parties have had the opportunity to have legal counsel review and fully explain the terms of this agreement. Mother is represented by Karl E. Rominger, Esquire of Rominger Law Office. 8. The parties hereto agree that this agreement shall be recorded and incorporated into an Order enforceable by the Court. 9. Consented to: 3 D to 311,610-2 Dale -,?-J,3, 0 7 Date 313-6-7? Date c SAa 'e L. P Karl E. Rominger, Esquire ,gg=r,?4 Adam S. Peters Witness for Adam S. Peter Q d S tL ? ?O oL MAR E3 2007 oP ? TA1VIlVlE L. PETERS, Plaintiff V. ADAM S. PETERS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. d 7 - j y 70 CIVIL IN CUSTODY ORDER OF COURT AND NOW, this day of r7'iD'1 , upon presentation and consideration of the within complaint and the stipulation and agreement incorporated therein, and upon agreement of the parties, it is hereby ordered and decreed as follows: 1. The parties shall have shared legal custody of the parties' minor children Tyler D. Peters, born 5/9/1999, and Alexus N. Peters, born 1/7/2003. 2. Mother shaft have primary physical custody of the children. 3. Father shall have partial physical custody of the children as follows: a. Father shall have periods of partial custody every other weekend from Friday beginning at 4:30 p.m. until Sunday evening at 7:30 p.m., the weekend of March 16, 2007. ?- b. The parties shall share Holidays by mutual Weement. N Distribution: E. Rominger, Esquire 155 South Hanover Street J Carlisle, Pennsylvania 17013 am S. Peters 5312 Oxford Circle, Apt. 6 Mechanicsburg, Pennsylvania 1705 J. c. U-1 CV T r_ ? cz? N TAMMIE L. PETERS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW ADAM S. PETERS, No.: 07-1470 CIVIL Defendant IN CUSTODY PETMON TO MODIFY CUSTODY 1. Petitioner is Tammie L. Peters who resides at 331 Greenspring Road, Newville, Cumberland County, Pennsylvania 17241. 2. Respondent is Adam S. Peters who resides at 5312 Oxford Circle, Apt. 6, Mechanicsburg, Pennsylvania 17055. 3. On March 26, 2007, the Honorable Edgar B. Bayley entered a Custody Order and Stipulation attached as Exhibit "A". 4. Since the entry of said Order, there has been a significant change in circumstances in that: a. One of the children has expressed an interest in not living with Father. b. Father's living conditions are not suitable for the children. c. The Petitioner has been and is best able to undertake and perform the primary parental responsibilities for the children. d. Petitioner is best able to provide a stable household for the children. e. Father is subjecting the children to an abusive paramour. f The children are constantly put in unsafe and unstable situations. 5. The best interest of the children will be served by the Court in modifying said Order. WHEREFORE, Petitioner prays this Court to grant the modification of the Custody Stipulation and Court Order of March 26, 2007, as follows: Petitioner is granted primary physical custody of Tyler and Alexus Peters with Father having periods of supervised visitation. Respectfully submitted, Rominger & Associates Date: February 21, 2008 Karl E. -Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Petitioner TAMMIE L. PETERS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW ADAM S. PETERS, No.: 07-1470 CIVIL Defendant IN CUSTODY VERIFICATION 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 Pa. Cons. Stat. § 4904 relating to unworn falsification to authorities. i ;a C4ie L. , P itio er 4 , TAMMIE L. PETERS, Plaintiff V. ADAM S. PETERS, Defendant LIAR 8 3 2007 444 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 6 7-/ y 70 CIVIL IN CUSTODY ORDER OF COURT AND NOW, this day of Xq AX A , , upon presentation and consideration of the within complaint and the stipulation and agree nt incorporated therein, and upon agreement of the parties, it is hereby ordered and decreed as follows: The parties shall have shared legal custody of the parties' minor children Tyler D. Peters, born 5/9/1999, and Alexus N. Peters, born 1/7/2003. 2. 3. a. b. Distribution: Mother shall have primary physical custody of the children. Father shall have partial physical custody of the children as follows: Father shall have periods of partial custody every other weekend from Friday beginning at 4:30 p.m. until Sunday evening at 7:30 p.m., beginning the weekend of March 16, 2007. The parties shall share Holidays by mutual agreement. Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 Adam S. Peters 5312 Oxford Circle, Apt. 6 Mechanicsburg, Pennsylvania 17055 TRUE Cr)PY FPOM RECORD In T ctim- ± my hand an ie T 4y) n (a, OG ? wU ..? i' thonotary' TAMNIIE L. PETERS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW ADAM S. PETERS, No. CIVIL Defendant IN CUSTODY ?-> yJ ..yJ f'y' COMPLAINT FOR CUSTODY 1. The plaintiff is Tammie L. Peters, residing at 331 Greenspring Road, Newville, 6*berlaAd County, Pennsylvania 17241. 2. The defendant is Adam S. Peters, residing at 5312 Oxford Circle, Apt. 6, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff seeks custody of the following child: Name Present Residence DOB Age Tyler D. Peters 331 Greenspring Road 5/9/1999 7 Newville, PA 17241 Alexus N. Peters 331 Greenspring Road 1/7/2003 4 Newville, PA 17241 The child Tyler was born out of wedlock and the daughter Alexus was born in wedlock. The children are presently in the custody of Mother, residing at 331 Greenspring Road, Newville, Cumberland County, Pennsylvania 17241. During the past five years, the children have resided with the following persons and at the following addresses: List All Persons List All Addresses Dates Adam S. Peters & 331 Greenspring Road 8/2001-6/2005 Tammie L. Peters Newville, PA 17241 Tammie L. Peters 448 Shed Road 6/2005-7/2006 Newville, PA 17241 Tammie L. Peters & 331 Greenspring Road 7/206-present Dennis Crutcher Newville, PA 17241 4 6 7 8. The mother of the children is Tammie L. Peters, residing at 3 31 Greenspring Road, Newville, Cumberland County, Pennsylvania 17241. She is not married. The father of the children is Adam S. Peters, residing at 5312 Oxford Circle, Apt. 6, Mechanicsburg, Cumberland County, Pennsylvania 17055. He is not married. The relationship of plaintiff to the children is that of Mother. The plaintiff currently resides with the following persons. Name Dennis Crutcher Relationship Boyfriend The relationship of defendant to the child is that of Father. The defendant currently resides with the following persons. Name Sheena Hollingsworth Ethan Hollingsworth Maddy Hollingsworth Relationship Girlfriend Girlfriends Son Girlfriends Daughter Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child and claims to have custody or visitation rights with respect to the child. The best interest and permanent welfare of the child will be served by granting the relief request because: A Court Order of custody and structured visitation is desired so that the Plaintiffand the child may plan their schedules accordingly, and so that misunderstandings and unmet expectations regarding custody and visitation can be avoided, and also so that the child is not used in a manipulative fashion. Plaintiff desires to maintain the family household which has been established, and the continued stability of the household is in the best interest of the child. A Court Ordered determination of custody is required to avoid continuing conflict between the parties regarding responsibility for custody and support. WHEREFORE, Plaintiff requests this Court grant Plaintiffprimary physical custody subject to partial custody by the Defendant. Respectfully submitted, Rominger & Associates Date: March 12, 2007 1 E. Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court I.D. # 81924 Attorney for Plaintiff TAMMIE L. PETERS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW ADAM S. PETERS, No. CIVIL Defendant IN CUSTODY VERIFICATION 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 Pa. Cons. Stat. § 4904 relating to unsworn falsification to authorities. Tammie L. Peters, Plaintiff TAMNIIE L. PETERS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW ADAM S. PETERS, No. CIVIL Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, attorney for Plaintiff do hereby certify that I this day mailed a copy of the within upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Adam S. Peters 5312 Oxford Circle, Apt. 6 Mechanicsburg, Pennsylvania 17055 Date: March 12, 2007 Respectfully submitted, Rominger & Associates fCvl E. Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court I.D. # 81924 Attorney for Plaintiff TAM IIE L. PETERS, Plaintiff V. ADAM S. PETERS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL. ACTION - LAW No. CIVIL IN CUSTODY STIPULATION AGREEMENT AS TO CUSTODY The plaintiff, Tammie L. Peters, hereinafter referenced as "Mother," and Defendant, Adam S. Peters, hereinafter referenced as "Father," hereby agree to the entry of the following terms in a Court Order defining custody and partial custody rights and responsibilities in relation to the parties' minor children, Tyler D. Peters, born 5/9/1999, and Alexus N. Peters, born 1/7/2003, hereinafter referenced as "Children": The parties hereto agree that the best interest and continuing welfare of the Children would be best served with the custody arrangement as follows: (a) Mother and Father will share legal custody of Children as defined in 23 Pa. C.S.A. §5302. All decisions affecting the Children's growth and development, including but not limited to medical treatment, education, and religious training, are major decisions which Mother and Father shall make jointly after discussion and consultation with each other. (b) As provided 23 Pa. C.S.A. §5309(a), each parent shall have full and complete access to the Children's mental, dental, religious and school records. This includes the names, addresses and telephone numbers of all medical and other providers. (c) Mother shall have primary physical custody of the Children. (d) Father shall have periods of partial custody every other weekend from Friday evening starting at 4: 30 p_m. until Sunday evening at 7:30 p.m., beginning the weekend of Friday, March 16, 2007. (e) The parties shall share holidays by mutual agreement. (f) Visitation may be at such other times as the parties mutually agree. 2. Each party shall have reasonable telephone and e-mail access to the Children while the Children are in the custody control of the parent. 3. The parties shall keep each other advised immediately relative to any emergencies concerning the Children and shall further take any necessary steps to ensure that the health, welfare and well being of the Children are protected. The parties shall do nothing that may estrange the Children from the other party or hinder the natural development of the Children's love or affection for the other parry. 4. Each party shall not make any disparaging remarks or allow others to make any disparaging remarks concerning the Children's parents in front of the Children. 5. Any modification or waiver of any of the provisions of the agreement of the parties shall be effective only if made in writing and only if executed with the same formality of the agreement of the parties. 6. 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. 7. Both parties agree that the terms of this agreement have been fully explained to them by their respective counsel or that both parties have had the opportunity to have legal counsel review and fully explain the terms of this agreement. Mother is represented by Karl E. Rominger, Esquire of Rominger Law Office. 8. The parties hereto agree that this agreement shall be recorded and incorporated into an Order enforceable by the Court. 9. Consented to: v C 1 ,f L 1. 1L Date axnmie L. Peters Dale Karl E. Rominger, Esquire .3-/3-C,7 4- ??? ._:e_ r Date Adam S. Peters Date Witness for Adam S. Peters TAMMIE L. PETERS, Plaintiff V. ADAM S. PETERS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No.: 07-1470 CIVIL IN CUSTODY CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, attorney for Plaintiff, Tammie L. Peters, do hereby certify that I this day served a copy of the Petition to Modify Custody upon the following by First Class Mail delivery at Carlisle, Pennsylvania, addressed as follows: Adam S. Peters 5312 Oxford Circle, Apt. 6 Mechanicsburg, Pennsylvania 17055 Respectfully submitted, Rominger & Associates Date: February 21, 2008 i Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Petitioner F•e 4. c. TAMMIE L. PETERS IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2007-1470 CIVIL ACTION LAW ADAM S. PETERS IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Thursday, February 28, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, March 28, 2008 at 1:00 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By; Isl ohMangan, Jr.,-E-s-I Custody Conciliator T The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites 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. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ?-? ? ?? ?, ? ? „?-?'? ?'? _?? moo. ?? ?, ??' - ,? ,? ? ???,? J? _ .j'. ,:....:. '. TAMIVIIE L. PETERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW ADAM S. PETERS, No. 07-1470 CIVIL Defendant IN CUSTODY STIPULATION AGREEMENT AS TO CUSTODY The plaintiff, Tammie L. Peters, hereinafter referenced as "Mother," and Defendant, Adam S. Peters, hereinafter referenced as "Father," hereby agree to the entry of the following terms in a Court Order defining custody and partial custody rights and responsibilities in relation to the parties' minor children, Tyler D. Peters, born 5/9/1999, and Alexus N. Peters, born 1/7/2003, hereinafter referenced as "Children": 1. The parties hereto agree that the best interest and continuing welfare of the Children would be best served with the custody arrangement as follows: (a) Mother and Father will share legal custody of Children as defined in 23 Pa. C.S.A. §5302. All decisions affecting the Children's growth and development, including but not limited to medical treatment, education, and religious training, are major decisions which Mother and Father shall make jointly after discussion and consultation with each other. (b) As provided 23 Pa. C.S.A. §5309(a), each parent shall have full and complete access to the Children's mental, dental, religious and school records. This includes the names, addresses and telephone numbers of all medical and other providers. (c) Mother shall have primary physical custody of the Children. (d) Father shall have periods of supervised custody every other weekend with no overnight visits. (e) Father shall visit with the children at a mutually agreed upon place. (f) Father will not permit the children to be around Sheena IJollingsworth, his paramour. (g) The parties shall share holidays by mutual agreement. (h) Visitation may be at such other times as the parties mutually agree. 2. Each party shall have reasonable telephone and e-mail access to the Children while the Children are in the custody control of the parent. 3. The parties shall keep each other advised immediately relative to any emergencies concerning the Children and shall further take any necessary steps to ensure that the health, welfare and well being of the Children are protected. The parties shall do nothing that may estrange the Children from the other party or hinder the natural development of the Children's love or affection for the other party. 4. Each party shall not make any disparaging remarks or allow others to make any disparaging remarks concerning the Children's parents in front of the Children. 5. Any modification or waiver of any of the provisions of the agreement of the parties shall be effective only if made in writing and only if executed with the same formality of the agreement of the parties. 6. 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. 7. Both parties agree that the terms of this agreement have been fully explained to them by their respective counsel or that both parties have had the opportunity to have legal counsel review and fully explain the terms of this agreement. Mother is represented by Karl E. Rominger, Esquire of Rominger Law Office. 8. 9 10 The parties hereto agree that this agreement shall be recorded and incorporated into an Order enforceable by the Court. This custody order shall remain in affect for a period of six (6) months from the date of execution and the parties then agree to follow the prior Order of Court dated March 26, 2007. The purpose of this agreement is to give Father an opportunity to change his circumstances sufficiently as to allow resumption of the previous agreement of the parties. 11. Consented to: Date N Date .T .71--OJV Date Date Q?I-Zwl ' Tammie L. Pet6rs Karl E. Rominger, Esquire Adam S. Peters Witness for Adam S. Peters i co Alt 25 20AQ0rr? TAIVIlMIE L. PETERS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW ADAM S. PETERS, No. 07-1470 CIVIL Defendant IN CUSTODY ORDER OF COU AND NOW, this day of 0AVLl-, 2008, upon presentation and consideration of the within stipulation and agreement incorporated therein, and upon agreement of the parties, it is hereby ordered and decreed as follows: 1. The parties shall have shared legal custody of the parties' minor children Tyler D. Peters, born 5/9/1999, and Alexus N. Peters, born 1/7/2003. 2. Mother shall have primary physical custody of the children. 3. Father shall have supervised visitation with the children as follows: a. Father shall visit the children at a mutually agreed upon place. b. Father shall have his visitation with the children every other weekend with no overnight visits. C. Father shall not permit the children to be around his paramour, Sheena Hollingsworth. d. The parties shall share Holidays by mutual agreement. e. Visitation may be at such other times as the parties mutually agree upon. f. This Custody Order will remain in affect six (6) months from the date of the execution of this Order. Thereafter the prio ust ted March 26, 2007, shall be automatically reinstated folio Distribution: `Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 dam S. Peters 5312 Oxford Circle, Apt. 6 Mechanicsburg, Pennsylvania 17055 an v'es matISCL J. N