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Home My WebLink About01-2906 FX MARYANNP, NEAL, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - LAW KAREN HEA THERL Y and PAUL J, COSTELLO, JR. Defendants : NO, 01-:2 90t CIVIL TERM : IN CUSTODY CUSTODY STIPULATION AND AGREEMENT THIS STIPULATION AND AGREEMENT entered into the day and year hereinafter set forth, by and between MARYANN P, NEAL, (hereinafter referred to as "Neal") and KAREN HEATHERLY, (hereinafter referred to as "Mother") and PAUL 1. COSTELLO, JR" (hereinafter referred to as "Father"), WHEREAS, Mother and Father are the natural parents of one child, Paul J. Costello, III, born April 21, 1984, (hereinafter referred to as "Child"); and WHEREAS, Neal is a party unrelated to the Child, but with whom the child presently resides; WHEREAS, the parties wish to vacate that prior Order and enter into an Order of Court based upon the within Stipulation and Agreement. NOW THEREFORE, in consideration of mutual covenants, promises and agreements as hereinafter set forth, the parties stipulate and agree as follows: I. Neal shall have primary physical and legal custody of the child, 2. Mother and Father shall each, independently, have periods of partial physical custody with the Child as the parties may agree, taking into consideration the desires of the Child. j,.- >'1- "..,-"",,. .'~-f- < " -',-F".."..-"- . ,-, - ~~ 3, The Child has resided for his entire life in Cumberland County, Pennsylvania, and Cumberland County has jurisdiction relative to custody of the child, 4. The parties desire that this Stipulation and Agreement be made an Order of Court of the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberland County does, in fact, have jurisdiction over the issue of custody of the Child, who has resided for his entire life in Cumberland County, Pennsylvania. 5. The parties stipulate that in making this Agreement, there has been no fraud, concealment, overreaching, coercion, or other unfair dealing on the part of the . other party, 6. The parties acknowledge that they have read and understand the provisions of this Agreement. Each party acknowledges that the Agreement is fair and equitable and that it is not the result of any duress or undue influence, IN WITNESS WHEREOF, the parties hereto intending to be legally bound by the terms hereof, set forth their hands and seals the day and year hereinafter mentioned, WITNESSETH: (aIM JoriuJ144Ctz1 ",..~o '-1 "-,_~""_' ''''Ie _T--" ~ 0'-',1'-" __.,e,,_. ._, .~ elf 1- dV{)(- , Q ~ Date M R~ . S~Lj-ol /OJ;tAOZ1 Ju MelUIYtb01 Date +(I-litness) / J/~h '-, /~l:t- '1'>.t, ""eLl COS~6, . . ~ ". ~~ "_0 tr - COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUlm l)evttthol On this 2~aYOf Afr! { ,2001, before me, the undersigned officer, personally appeared MARYANN P. NEAL, known to me (or satisfactory proven) to be the person whose name is subscribed to the within Agreement and acknowledged that she executed the same for the purpose therein contained, IN WITNESS WHEREOF, I hereunto set my hand and official seal. -~ ~~~ Karisa J, Lehman, Notary PubIl. C r~ Carlisle Boro, CUmberlaniI Cou ' . My Commission expires Aug, 25, ~ otary Pub ' 1- COMMONWEALTH OF PENNSYLVANIA COUNTY OF (lI\, V'V\ De,,, lu\NY{ On this -4-tb day of ~ , 2001, before me, the undersigned officer, personally appeared KAREN HEATHERLY, known to me (or satisfactory proven) to be the person whose name is subscribed to the within Agreement and acknowledged that she executed the same for the purpose therein contained, IN WITNESS WHEREOF, I hereunto set my hand and official seal. l~f0~-Vl tary Public NoIIu1aI Seal Karisa J, Lehman, Notary Public Ca.rffsle Bora, CumbeI1and County My Commission ExPJres Aug. 25, 2003 ;"".- - r '_'," ~~_'''' ,,? __or - '0".', - 1,-. ~ , .. - ,~~ ST A IE OF FLORIDA COUNTY OF m/f)Z /0 J/ On this jf?'dayof f/;1 /2; /-. , 200 I, before me, the undersigned officer, personally appeared PAUL J. COSTELLO, JR., known to me (or satisfactory proven) to be the person whose name is subscribed to the within Agreement and acknowledged that he executed the same for the purpose therein contained, IN WITNESS WHEREOF, I hereunto set my hand and official seal. ~- ,-:. ,'","" ,';,.,~:,:, <'" ,', ,"-" , ,-, ." " ....- ~ .~, 'r,,'" , . p>:;> ~ .~ ~-"..~ ., ',,' '" ...",....." ,.,~"~~..w""'r'..~T 1U1i1r..Tr..n':....~r..'1'!(j ~ ~ ~ 0 '";, Z;? .... 8 c: ?:, ::!: -OCI. :C::I" ~-[~:. .-;;:. ....... ~ C3 ~~~ ) ~l.'; ...... SU ...... C~C.I ~"""'1 ~ ~ -,">< ;i'" ) ll' ~'~'..,. C j ';', r :;t~ , ( ~,.>: - ~~~, :.-j (..; 2. -< $:: ~ lMI:~ ,W", ,- [l~~~~,'$4~jJ~\'f;:jJ!il",,~w.:--'lf~JII!I~R~i)<ii'H!\~!f~J;)''''''"'H',.-'~'''';-'^';,-m''''F'~,-"'''''"'3~{' ,c,,'k<' ,"'Vi~'f,~"'~'1tF.-"'~\'!i,'ee:W!~^)""~''''',)".",';''~,i'(~:;;1,\!\J'-'l~Wf'''')jj~~;~ MARYANNP, NEAL, Plaintiff IN THE COURT OF COMMON PLEPMJ\YF1 fi 2001Jt7 CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - LAW KAREN HEA THERL Yand PAUL 1. COSTELLO, JR, Defendants : NO.O/-:t'iOb CIVIL TERM : IN CUSTODY ORDER OF COURT AND NOW this 111^--day of M Q , 2001, upon presentation and consideration of the Stipulation and Agreement is hereby ordered and directed that the attached Stipulation and Agreement is hereby made an Order of Court with all prior Orders and Agreements being vacated, BY THE COURT .~ ~ cc: Bradley 1. Griffie, Esquire Attorney for Plaintiff crt (\D\ " Karen Heatherly, Defendant,pro se Paul J. Costello, Jr., Defendant, pro se -f..-":,.,. -''1'l'' _ >1..,,'1'_1;_' Nit ~', I , , ~ ,~~ ,'" ~ - ~- t~ . rf'l. " rYJ .4(-- I"-,~ - !:f'~ ,'. ,~. liiNI1Al},SNN3d 'J'ln"''"' n;, ".r" '.'Y'j'/.In" f\. .I', )IJ,,,.I ':-\',1 ,.'::,.<,~, ~~, 1\..) 871 r I j ,'\ l1"'I.l In 1:6 \-'~\;, L I f. 'J l'~ i lJ t}J\ilC::< > . .~"', <~ ""-_'>>_"'A ,"-?,.~' " -~,' "'u"",' ,c.,~-"~'--'- "'~r"-'"']iJr'~fJtl];-'_t ~'::'.. '~:I'::'; .~ ~, -,~ ~~ilffl<'-Jf"M.~~~'''''''''~'''li''--W"'"-:~W11'')':;;!'''';'";''_''''''' ",<~ 'C;j""*"P"'~Il',IW ;O"~"",~;._,,"'e"' -~" "'''~'_'''-~1''iI'.''H~''Ill'',~'''?!);7'ir::-ry;'Y