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HomeMy WebLinkAbout01-5944SHARON THOMAS, Plaintiff JOHANNA M. CRAVER, Defendant : iN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. ~1. - .~ / CIVIL ACTION - LAW IN CUSTODY STIPULATION FOR AN AGREED ORDER OF CUSTODY AGREEMENT, made this I ) ~ day of C)o4--o ~ ,2001, by and between SHARON THOMAS, hereinafter referred to as "Maternal Great Aunt," and JOHANNA M. CRAVER, hereinafter referred to as "Mother." WHEREAS, Defendant is the natural mother of one minor child, TANICA C. L. CRAVER, born January 5, 1985; and WHEREAS, the child was born out of wedlock, the natural father has never been involved with the child's life and the whereabouts of the father are 3resently unknown; and WHEREAS, the parties have come to an agreement concerning the ~ssues of child custody; and WHEREAS, the parties desire that this Stipulation be entered as an Order by the Court of Common Pleas of CumberLand County, Pennsylvania; NOW THEREFORE, intending to be legally bound, the parties hereby stipulate and agree as follows: 1. Maternal Great Aunt shall have primary legal custody of the minor child, TANICA C. L. CRAVER, legal custody being defined as the legal right to make major decisions affecting the upbringing of the child, including but not limited to medical, religious, and educational decisions. 2. Mother has a right to be kept informed of the child's educational and medical development, and shall have a right of access to the child's educational and medical records. Mother shall be entitled to complete and full information concerning the child from the Maternal Great Aunt and from any doctor, dentist, teacher or similar authority, and to have copies of any reports, notices or other communications given to Maternal Great Aunt as the individual having custody of the minor child. 3. Maternal Great Aunt shall notify the other of any matter relating to the child, which could reasonably be expected to be of significant concern to the other party. 4. Day-to-day decisions shall be the responsibility of the Maternal Great Aunt, who has primary legal custody. PHYSICAL CUSTODY 5. Maternal Great Aunt shall have primary physical custody of the minor child, primary physical custody being defined as actual physical possession and control of the child. Mother shall have visitation rights with the child, visitation being defined as the right to visit with the minor child, but does not include the right to remove the child from the custodial person's home without the consent of the custodial person. 6. Beginning at the age of two years and up until July 27, 2000 when the maternal grandmother suffered a stroke, the minor child lived primarily with the maternal grandmother, but she had frequent and continuous contact with the Plaintiff and lived for a period of time with MARY JANE THOMAS, the sister of the Defendant and the niece of the Plaintiff. 8. Due to the maternal grandmother's stroke and MARY JANE THOMAS' inability to care for the minor child at this time, the parties hereto seek to formally place custody of the minor child with the Maternal Great Aunt so that the child may be enrolled in school for the 2001-2001 school year, and so that the Maternal Great Aunt may provide health insurance and other benefits to the minor child. 9. Neither party shall impair the other party's right to physical custody or interfere with the other party's physical custody when the child is with that party. 10. Neither party shall disparage the other party in front of the child, whether the child is "sleeping" or "awake," nor shall either party attempt to alienate the affections of the child from the other party or allow third parties to attempt to alienate the affections of the child from the other party. WHEREFORE, the parties request that this Stipulation be entered as an Order of the Court. Witness Witness anna M. Craver ~h,~o m~~;~'''' 4 SHARON THOMAS, Plaintiff JOHANNA M. CRAVER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY AND NOW, this :zz,~ day of ~ ,2001, it is hereby ORDERED AND DECREED that the attached Stipulation for an Agreed Order of Custody is made an Order of Court and said Stipulation is adopted in its entirety and incorporated herein as an Order of Court. Dated: BY THE COURT: VINVA'IASNN~d A.INNO0 01:8 I,t~' ~ .I.30