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HomeMy WebLinkAbout01-04357IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BETH A. RADCLIFFE, Plaintiff, vs. JAMES J. RADCLH+FE, Defendant. CIVIL ACTION -LAW NO. ®J, i~3~ IN CUSTODY ORDER OF COURT ~ 1 NOW, J v ~ , 2001, upon consideration of the within Stipulation anct Agreement, it is hereby ordered as foll s: 1. Beth A. Radcliffe ("Mother") shall have sole legal and residential custody of the child, Trent J. Radcliffe, born June 29, 1995 ("the child") until further Order of Court. 2. Father may be entitled to periods of visitation as Mother and Father shall mutually agree. 3. The parties agree that Father shall not presently pay child support for the fmancial support of the said Trent J. Radcliffe: The parties presently acknowledge and agree, however, that this agreement is subject to modification by the Court at a future point in time based on what is deemed to be in the best interest of the child. 4. The costs of this proceeding have been paid by Mother. J. .. WEIGLE, PERKIN6 6c ASSOCIATES -ATTORNEYS AT LAW - 126 EAST KING STREET - 6HIPPENSBURG, PA 19267-1397 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BETH A. RADCLIFFE, Plaintiff, vs. JAMES J. RADCLIFFE, Defendant. CIVIL ACTION -LAW NO. IN CUSTODY STIPULATION AND AGREEMENT This Stipulation and Agreement is made this ~ f~ day of , 2001, by and between Beth A. Radcliffe, of 27 South Penn Street, Shippensburg, Cumb land aunty, Pennsylvania 17257, (hereinafter referred to as "Mother") and James J. Radcliffe, of 103 North Penn Street, Apartment #6, Shippensburg, Cumberland County, Pennsylvania 17257, (hereinafter referred to as "Father"). 1. Beth A. Radcliffe and James J. Radcliffe are the natural parents of Trent J. Radcliffe, born June 29, 1995, hereinafter referred to as "the child". 2. Beth A. Radcliffe and James J. Radcliffe were married at the time of the birth of the child. 3. The child is presently in the care and custody of Mother. 4. None of the parties know of any person not a party to the proceedings who has physical custody of the child, or claims to have custody or visitation rights with respect to the child. 5. During the last five years, the child has resided with the following persons and at the following addresses: NAME ADDRESS DATE Beth A. Radcliffe (mother) 27 South Penn Street 6/29/95 - 5/5/97 and James J. Radcliffe (father) Shippensburg, PA 17257 Beth A. Radcliffe (mother) 27 South Penn Street 5/6/97 - 8/30/00 Shippensburg, PA 17257 Beth A. Radcliffe (mother) 27 South Penn Street 8/31/00 - 12/15/00 and James J. Radcliffe (father) Shippensburg, PA 17257 Beth A. Radcliffe (mother) 27 South Penn Street 12/16/00 -present Shippensburg, PA 17257 WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 1]25']-1399 6. The parties have reached an agreement with regard to the custody of the child 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 aze 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, -J d'.3 2001, upon consideration of the within Stipulation and Agreement, it is hereby ordered as follows: Beth A. Radcliffe ("Mother") shall have sole legal and residential custody of the child, Trent J. Radcliffe, born June 29, 1995 ("the child") until further Order of Court. Father may be entitled to periods of visitation as Mother and Father shall mutually agree. The parties agree that Father shall not presently pay child support for the financial.support of the said Trent J. Radcliffe. The parties presently acknowledge and agree, however, that this agreement is subject to modification by the Court at a future point in time based on what is deemed to be in the best interest of the child. 4. The costs of this proceeding have been paid by Mother. By the , 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, execute this Agreement by signing below. fitness BETH A. RADCLIFF W' ess J ES J. RA CLIFF WEIGLE, PERKINS 6 ASSOCIATES -ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPEN6BURG, PA 1]25]-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: l (e !Ol ~~ a~ BETH A. RADCLIFFE 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: ~" 3 - (r; ~'^~ J MES J. 'FE WEIGLE, PERKIN6 6 ASSOCIATES -ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17267-1397 wq