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HomeMy WebLinkAbout01-03340 II IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KIMBERLY SUE TRITT Plaintiff, CIVIL ACTION - LAW vs. NO. 0/- 33 'to &:d /.w-- WILLIAM H. TRITT, JR., Defendant. IN CUSTODY STIPULATION AND AGREEMENT This Stipulation and Agreement is made this ~O ()\ day of '1'Y\ a.i.I-- ' 2001, by and between Kimberly Sue Tritt of 2295 Orrstown Road, Shippensburg, SouthaJ4iPton Township, Franklin County, Pennsylvania 17257, (hereinafter referred to as "Mother") and William H. Tritt, Jr., of 40 Horsekiller Road, Shippensburg, Cumberland County, Pennsylvania 17257, (hereinafter referred to as "Father"). 1. Kimberly Sue Tritt and William H. Tritt, Jr., are the natural parents of Amanda Jane Tritt, born June 13, 1986; Amber Jo Tritt, born November 10, 1989; and Tiffany Lee Tritt, born December 8,1991, hereinafter referred to as "the children". 2. The children, Amber Jo Tritt and Tiffany Lee Tritt, are presently in the care and custody of Mother. Amanda Jane Tritt has been in the care and custody of Father since March 2000. 3. During the last five years, the children have resided with the following persons and at the following addresses: NAME ADDRESS DATE Kimberly S. Tritt 1184 Mainsville Road May 1995 to Shippensburg,P1\ 17257 February 1997 Kimberly S. Tritt 1184 Mainsville Road February 1997 to Merrill E. Varner, Jr. Shippensburg, P 1\ 17257 February 2000 Kimberly S. Tritt 2295 Orrstown Road February 2000 to Merrill E. Varner, Jr. Shippensburg, P 1\ 17257 September 2000 Kimberly S. Tritt 216 Clearfield Road . Septem.ber 2000 to Shippensburg, P 1\ 17257 January 2001 Kimberly S. Tritt 2295 Orrstown Road January 2001 to Merril E. Varner, Jr. Shippensburg, P 1\ 17257 Present WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257~1397 ,~ "'~ -,~ " ." ., ,,',-_ _, >-_-. ._" r,,-" -.1- " r . 4. Mother has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Mother has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Mother does not know of a person, not a party to the proceedings, who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 5. The best interest and permanent welfare of the children will be served by granting the relief requested. 6. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. All other persons, named below, who are known to have or claim a righUo custody or visitation of the children will be given notice of the pendency of this action and the right to intervene: NAME None ADDRESS BASIS OF CLAIM 7. The parties have reached an agreement with regard to the custody of the children and desire to reduce their agreement to an Order of Court. NOW THEREFORE, the parties intending to be legally bound and waiving their right to be present when this Agreement and Order are presented and executed hereby stipulate and agree that the Court may enter the following Order of Court in the above-captioned case: ORDER OF COURT NOW, , 2001, upon consideration of the within Stipulation and Agreement, it is hereby ordered as follows: 1. Kimberly S. Tritt ("Mother") and William H. Tritt, Jr., ("Father") shall have shared legal custody of the children Amanda Jane Tritt, born June 13, 1986; Amber Jo Tritt, born November 10, 1989; and Tiffany Lee Tritt, born December 8, 1991 (the "children"). 2. Mother shall have primary physical custody of Amber Jo Tritt and Tiffany Lee Tritt. Father shall have partial custody every Monday evening from 6:00 P.M. until 9:30 P.M. and such other times as the parties from time to time may mutually agree. WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 'j" II . 3. Father shall have primary physical custody of Amanda Jane Tritt and Mother shall have partial custody and liberal visitation at such times as the parties from time to time may mutually agree. 4. The parties shall cooperate in arrangmg for a sharing of custody on major holidays. 5. The costs of this proceeding have been paid by Mother. By the Court, J. The parties further agree that, in procuring this Agreement, there has been no fraud, concealment, overreaching, coercion, or other unfair dealing on the part of the other. IN WITNESS WHEREOF, the parties, intending to be bound by the terms and conditions of this agreement, eJ.<!:< this Agreement by signing below. ~lmhu~&u 1 ~I'ij- KI ERLY S TT )f~ dt-~. Witness Cj.lp~~; WILLIAM H. T, JR. WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPEN5BURG, PA 17257~1397 - " ,- I verify that the statements made in this Stipulation and Agreement are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Dated: ma~:\o ,.;)N')L I ~'<i>~ ~ ~tt KIMB RLYS. T T I verify that the statements made in this Stipulation and Agreement are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to falsification to authorities. Dated:_18 (Y'lo.-1 ~OO l ~R~ WILLIAM H. TRITT, JR. WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 " ,- .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KIMBERLY S. TRITT Plaintiff, CWIL ACTION - LAW VS. NO. 0/- '33</c) WILLIAM H. TRITT, JR. Defendant. IN CUSTODY ORDER OF COURT NOW, :r \,....(. .., , 2001, upon consideration of the within Stipulation and Agreement, it is hereby ordered as follows: 1. Kimberly S. Tritt ("Mother") and William H. Tritt, Jr., ("Father) shall have shared legal custody of the children Amanda Jane Tritt, born June 13, 1986; Amber Jo Tritt, born November 10, 1989; and Tiffany Lee Tritt, born December 8,1991 ("the children"). 2. Mother shall have primary physical custody of Amber Jo Tritt and Tiffany Lee Tritt. Father shall have partial custody every Monday evening from 6:00 P.M. until 9:30 P.M. and such other times as the parties from time to time may mutually agree. 3. Father shall have primary physical custody of Amanda Jane Tritt. Mother shall have partial custody and liberal visitation at such times as the parties from time to time may mutually agree. 4. The parties shall cooperate in arranging for a sharing of custody on major holidays. 5. The cost of this proceeding has been paid by Mother. 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