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Home My WebLink About01-2715 FX _, __~"_'-'" > ,.,--,-", -'< ^ '",,".- "', '""J" ',__ "/ ". ,,c. - "d'._','-,,,;,, ,'^,"~.' ~" ,- - '" 0' 'i,,', ,~,",,,-; ,",',' ""~"'. c ,,'!t';;:L'..::'_~.:';'~~, ""'0' '",'-,' ,!'"_,'~;"-",';'__,;.;;i,;';t~,,,,li;,~I:j;:,~~"'--",~;"'~ ", -~'"~ "'t;, , TRACIE E. DERR, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. I!J J. ;( 7/j- CIVIL TERM ROBERT L. DERR, Defendant : CIVIL ACTION - LAW : IN CUSTODY STIPULATION FOR CUSTODY WHEREAS, the Plaintiff and Defendant are the parents of two minor children, to wit: Brooke Derr, born November 23, 1993, and Tyler Derr, born June 25, 1997; 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 these children 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 these children; NOW THEREFORE, intending to be legally bound, the parties agree as follows: 1. Plaintiff; Tracie E. Derr, and Defendant, Robert L. Derr, shall have shared legal custody of Brooke Derr, born November 23, 1993, and Tyler Derr, born June 25, 1997. Eachparent shaI1 have an equal right, to be exercised jointly with the other parent, to make all major non- emergency decisions affecting the children's general well-being including, but not limited to, all decisions affecting the children's health, education, and religion. Pursuant to the terms of this ,,' . -i ''''', ~,___ ~.,___ 'h,_ .'" ~,-,__, ,'~",:' ',- ",,'-,' ',,",'>".' n'" ,0' "~":'-__",'~f",,,,:1,,,.._; "'e;"''- '--';<'[-~;::'iL,:'';{''".;':,::'C;'-;; ',' __'' ,~__ ';.>;"', ,~;;",,, ""';, ~." __''''-.<<: paragraph, each parent shall be entitled to all records and information pertaining to the children, including, but not limited to, school and medical records and information. 2. Plaintiffand Defendant shall have shared physical custody of the minor children. Each parent shall have the children for seven (7) consecutive days at which time, physical custody shall transfer to the other parent. The transfer of physical custody shall take place on Fridays, with the exact location and the exact times oftransfer to be at the discretion ofthe parties. This schedule sha11 begin on May 18, 2001. 3. Holidays shall be shared between the parties upon the following schedule: A. Plaintiff shall be entitled to visitation on Mother's Day and Defendant shall be entitled to visitation on Father's Day, with the exact details to be determined by the parties. B. The parties shall share custody of the children on the Christmas holiday as follows: 1. Schedule A: From 6:00 p.m. on Christmas Eve until I :00 p.m. on Christmas Day; and 2. Schedule B: From I :00 p.m. on Christmas Day until 6:00 p.m. on December 26th. Plaintiff shall exercise her period of custody over the children in accordance with the Schedule A provisions. Defendant shall exercise his period of custody over the children in accordance with the Schedule B provisions. . ".'~ ~-" --,~~. -;,;;;:1.' '" "" - '1'-," ", ,.0.-;" ;,'",,,.-,,, "F,,;,~' "~:,,,:,.,~,.,,~;o''''''''''o~;;~ ",.,:~:""",;,,~;,,",;;,,,~'-,!"~:,~;,.:-:;'__,,~~';i~3~;i';( .'~''':'' _';"', _ '. C. The following major holidays shall be equally divided between the parties, with the exact details of such to be detennined by the parties: New Year's Day, Easter, Memorial Day, July Fourth, Labor Day, and Thanksgiving Day. D. Any additional periods of physical custody which the parties may agree upon. 4. The parties shall keep each other informed of their respective current addresses and telephone numbers. 5. Both parties shall encourage the children to love and respect the other and shall not make, nor allow others to make, in the presence of the children, derogatory comments about the other parent. Further, each parent shall encourage the children to have significant contact with the other parent, and shall make certain that the children are ready on time for the transfer of physical custody of the children from one parent to the other. 6. 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 and/or house guests comply with this prohibition. 7. This agreement has been reached after careful consideration of the needs of the children. The parties agree that they shall not seek to change this shared custody arrangement unless this arrangement constitutes a clear and present danger to the physical or emotional well-being of the children. 8. Plaintiffis represented by CaraA. Boyanowski, Esquire. Defendant is not represented 0'0 '< , _0' ~,"_ ",,"__~ ,', '*, _, 'c ""'~"_ '-~ ,g",.j':,,{ '.,,~: :"'"iFO" ",',;' ~:" ',~;,,,--,,,"~C::'-~;",~~~j~~ ,,'0; '~. ,','; ,- ,--~--"-- '4 by counsel. All parties have been informed of the purpose of this Agreement and its legal effects and consequences. 9. Each of the parties has carefully read and fully considered this Stipulation and all of the statements, tenns, conditions, and provisions thereof prior to signing below. IN WITNESS WHEREOF, intending to be legally bound hereby, the parties hereto have set their hands and seals on this ;;:. net day of 2001. WITNESS: JAlM 0but Tracie E. Derr ~r1~ ' Robert L. " '. - ,-, ,~ _~~'" ,. 'J" _ '" _ ,,-,C ;h >--',.." ,'''_'~,:,~O~ ,~,.~'ob--' .' ,,- ,-,,~ -"7,,"', ,'~~"- ~k"'" '....'. ',-" ,,--- , ,"-'~, ,".J"~ '--"-,""'" ,"'~_-';;~,> "f." ,;',;',~,i,:';-',Jc',~-;l-';':;: ,'~,;;-; '"c--, '" "--"'--'( . TRACIE E. DERR, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO.OI - .:nAS CIVIL TERM ROBERT L. DERR, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this '1~ day of ('1\7 ,2001, upon stipulation of the parties, it is hereby Ordered and Decreed: 1. Plaintiff, Tracie E. Derr, and Defendant, Robert L. Derr, shall have shared legal custody of Brooke Derr, born November 23, 1993, and Tyler Derr, born June 25, 1997. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non- emergency decisions affecting the children's general well-being including, but not limited to, all decisions affecting the children's health, education, and religion. Pursuant to the terms of this paragraph, each parent shaI1 be entitled to all records and information pertaining to the children, including, but not limited to, school and medical records and information. 2. Plaintiffand Defendant shall have shared physical custody of the minor children. Each parent shall have the children for seven (7) consecutive days at which time, physical custody shall transfer to the other parent. The transfer of physical custody shall take place on Fridays, with the exact location and the exact times of transfer to be at the discretion of the parties. This schedule shall begin on May 18, 2001. Ii ~ > - . '~,"'" " " -"i -' ~"" , -'>-__'"' ,",'T", .', ~,"' '.'"",",'.~,J",,_: -,-',~, ~,;", '" - , 1"2 _',,,;~,,;,~-, ~;o:, >~'-.~';'^"~"''''''__''''';;'_ " ", "--" ,,~, :irf 3. Holidays shall be shared between the parties upon the following schedule: A. Plaintiff shall be entitled to visitation on Mother's Day and Defendant shall be entitled to visitation on Father's Day, with the exact details to be determined by the parties. B. The parties shall share custody of the children on the Christmas holiday as follows: 1. Schedule A: From 6:00 p.m. on Christmas Eve until 1 :00 p.m. on Christmas Day; and 2. ScheduleB: From 1:00 p.m. on Christmas Day until 6:00 p.m. on December 26th. Plaintiff shall exercise her period of custody over the children in accordance with the Schedule A provisions. Defendant shall exercise his period of custody over the children in accordance with the Schedule B provisions. 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. D. Any additional periods of physical custody which the parties may agree upon. 4. The parties shaIl keep each other informed of their respective current addresses and telephone numbers. ,-- ~ ' "'--'^, ''" ~,-- '~', .'-'n ,<" " __, h--"__,'~ _" ~",'" -,~' ."("';1--,,,,,," '_'_ ~,,' ~""', ,.. '<0";;:;-:' ,'~',:'" j'~",c.'~ \,.-,~ ';';"";"~_'._~'"",-:,""""--' ''-,-':-;}iJ~,',':'." -"'''; 5. Both parties shall encourage the children to love and respect the other and shall not make, nor allow others to make, in the presence of the children, derogatory comments about the other parent. Further, each parent shall encourage the children to have significant contact with the other parent, and shall make certain that the children are ready on time for the transfer of physical custody of the children from one parent to the other. 6. 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 and/or house guests comply with this prohibition. 7. This agreement has been reached after careful consideration of the needs of the children. The parties agree that they shall not seek to change this shared custody arrangement unless this arrangement constitutes a clear and present danger to the physical or emotional well-being of the children. T: x J. o"oq ~~mloo~~i'ii<~'li";~-.i 4)"- k:p --'>', .,", ,. Ah'""" ,""M'- "'- _~p. ";~~~'" ViN' "-jl 8""-1 ' VI 111\ f\\ i'-ii\!:c }.JNnO:J Oi')\-(:!~}?;j[.I\JnO ! 0 ,'f)' I.....', ',~, ' , I' J !,' _ ,~l t~- r~/i 1;) AU'/L~~~' --'.-" ,~ " ~,' ""', .'~' -........-..;.;.;.11.: ~...""~ -, " , ~ - ~ ~ -"'=-', '1 I I I i , , I i .Ii