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Home My WebLink About01-04272IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MICHAEL J. FRANZ, Petitioner v. DAWN M. POGUE, Respondent CIVIL ACTION -LAW N0.2001- ~F17y ~'.c.~=B ~c4,[.- IN CUSTODY ORDER OF COURT AND NOW, this I ~~ day of , 2001, pursuant to a Stipulation and Custody Agreement reached by the parties IT IS HEREBY Ordered and Duected as follows: 1. FATI-IER and MOTHER shall share legal custody of their minor children, HANNAH JACOBY FRANZ and SUMMER MEADOWS FRANZ, and pursuant to this grant of shared legal custody, each parent shall have equal access to all pertinent information and reports that may be generated by medical, educational, psychological and other professionals who may work with their child. Each parent shall discuss major decisions effecting the children's well being in the areas of medical, educafional, emotional, spiritual, social, and material needs with the opposite parent. 2. FATHER shall have primary physical custody of HANNAH and SUMMER. 3. Except as provided hereinbelow,MOTHER shall have partial custody F\USrFOItletlFi~m OCC[\Gentloce21M11\2284-IQa,l,w(d ` of the children as can agreed. 4. Custody during Holidays shall be shared equally. 5. The parties shall each have a reasonable period of time with the children on their birthdays and on the children's birthday to celebrate these events. 6. Neither Party shall move his or her residence from Cumberland County, Pennsylvania, without first giving sixty (60) days' notice to the other Party. At that time, either Party can petition the Court of Common Pleas of Cumberland County, Pennsylvania for modification of custody, if necessary. 7. Neither party shall do anything which may estrange the children from the other parent, or injure the opinion of the children as to the other parent or which may hamper the free and natural development of the children's love or respect for the other parent. BY THE RT: J. Richard L. Webber, Jr., Attorney for Petitioner Dawn M. Pogue, Respondent, Pro Se F:fUU~PddetlFi'mlJy~~,.~pp~g200f~2284-1aac.l.wpi 2 .0,''" ~~S C . ~-~- I a .".'.rF r ,vn.., ngll l~,~ t ~ Vi~~%', qf,,/' ~~1'~ ~~ _, k,V III ~l -., i t. _ ~+a«mRwwo;~N~M~HI:i~;?.?~~fl~fis~gMFx .. ... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MICHAEL J. FRANZ, Petitioner CIVIL ACTION -LAW v. IV0.2001- ~f.272, (~ T,u.y- DAWN M. POGUE, Respondent 1N CUSTODY PETITION FOR ENTRY OF AGREEMENT AND NOW come the Petitioner, MICHAEL J. FRANZ, by and through his attorneys, The Law Office of Michael J. Hanft, and files this Petition pursuant to Pa.R.C.P. No. 1915.7, averring the following: 1. Petitioner is MICHAEL J. FRANZ, who resides at Lot 80, 7073 Carlisle Pike, Carlisle, Cumberland County, Pennsylvania 17013. 2. Respondent is DAWN M. POGUE, who resides at 1343 Grandview Court, Carlisle, Cumberland County, Pennsylvania 17013. 3. The Petitioner and Respondent are natural parents of HANNAH JACOBY FRANZ, born September 29, 1998 and SUMMER MEADOWS FRANZ, born August 10, 2000. 4. On or about June 29, 2001, the parties entered into an Agreement regarding custody of the children. Said Agreement is attached hereto and incorporated by reference herein. 5. The parties desire the entry of an Order of Court reflecting the terms of the Agreement. F1USUPOIOe~Ficm DOCe1GeM0u200112284-2eNry.l.w(d 1 WIIEREFORE, Petitioner requests your Honorable Court to approve the attached Agreement and enter it as an Order or Court. Date: ~~J 9~oi Respectfully submitted, LAW OFFICE OF MICHAEL J. HANFT '~,;Jrz..~.a~~ Richard L. Webber, Jr. Attorney for Petitioner 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013-9142 (717)249-5373 VERIFICATION I verify that the statements made in this Pefition for Entry of Agreement are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. Richard L. Webber, Jr., Atto y for Petitioner P:\UeerFOlEet~Fi~m DOGS\Gevbc4001\ll80.3¢Wry.l,svpi 2 CUSTODY AGREEMENT AND STIPULATION THIS AGREEMENT, made this a 9f day of J ~,,~ F 2001, by and between MICHAEL J. FRANZ, of Cumberland County, Pennsylvania, parry of the first part, hereinafter referred to as "FATHER," and DAWN M. POGUE, of Cumberland County, Pennsylvania, party ofthe second part, hereinafter referred to as "MOTHER," or collectively referred to as "the Parties." WHEREAS, FATHER and MOTHER desire to provide for the custody of their children, HANNAH JACOBY FRANZ, born September 29,1998, hereinafter referred to as "I IANNAH",and SUMMER MEADOWS FRANZ, born August 10, 2000, hereinafter referred to as "SUMMER"; WHEREAS, the children have resided in Cumberland County, Pennsylvania, since birth; WHEREAS, neither party has information of a custody proceeding concerning the children pending in a court within or outside this Commonwealth; and WHEREAS, neither party knows of any other person who has physical custody of the children or claims to have custody or visitation rights with respect to the children. NOW, THEREFORE, the Parties, in consideration of the mutually made and to be kept promises set forth herein and for other good and valuable consideration, intending to be legally F\UUe FO1tlMF4m UCCeICreMOCS3W1\238<-ICUmgreemml.wptl 1 bound and to legally bind their heirs, successors, assigns, and personal representatives, do hereby covenant, promise and agree as follows: FATHER and MOTHER shall share legal custody oftheir minor children, HANNAH JACOBY FRANZ and SUMMER MEADOWS FRANZ, and pursuant to this grant of shared legal custody, each parent shall have equal access to all pertinent information and reports that may be generated by medical, educational, psychological and other professionals who may work with their child. Each parent shall discuss major decisions effecting the children's well being in the areas of medical, educational, emotional, spiritual, social, and material needs with the opposite parent. 2. FATHER shall haue primary physical custody of HANNAH and SUMMER. 3. Except as provided hereinbelow,MOTHER shall have partial custody ofthe children as can agreed. 4. Custody during Holidays shall be shared equally. 5. The parties shall each have a reasonable period of time with the children on their birthdays and on the children's birthday to celebrate these events. 6. Neither Party shall move his or her residence from Cumberland County, Pennsylvania, without first giving sixty (60) days' notice to the other Party. At that time, either Parry can petition the Court of Common Pleas of Cumberland County, Pennsylvania for modification of custody, if necessary. Neither party shall do anything which may estrange the children from the other parent, or injure the opinion of the children as to the other parent or which may hamper the free and natural development of the children's love or respect for the other parent. F:\UUC Foltlet~Fi~m UacsMceMOO11p l\238<-ICUS~®¢eemml.w~d 8. The parties agree that the terms of this Custody Agreement and Stipulation shall be entered as an Order of Court. IN WITNESS WHEREOF, the Parties have set their hands and seals the day and year first above written. WITNESSED BY: /\ (SEAL) Michael J. Fr ~' . ~ (SEAL) cDawn M. Pogue F:\IItte FOltlel\F4m Dace\Geq{a,5yLb1U384~lcumgrementwptl