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HomeMy WebLinkAbout03-2541TERESA J. DUNCAN, Plaintiff TONY Q. OWEN, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · CIVIL ACTION - LAW · IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is Teresa J. Duncan, residing at 232 Stonehedge Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055· 2. The Defendant is Tony Q. Owen, residing at 1705 Kathryn Street, New Cumberland, Cumberland County, Pennsylvania 17070· 3. Plaintiff seeks custody of the following child: Name Present Residence Date of Birth Danielle Kaye Owen 1705 Kathryn Street May 26, 1997 New Cumberland, PA 17070 o The child was bom out of wedlock. The child is presently in the custody of Tony Q. Owen, Defendant herein, who resides at 1705 Kathryn Street, New Cumberland, Cumberland County, Pennsylvania 17070. 6. During the past five (5) years, the child has resided with the following persons and at the following addresses: Nanle Teresa Duncan Tony Owen Danielle Owen Rebecca Bahrenburg .Address 4518 Rolo Court Mechanicsburg, PA 17055 Dates 5/26/97 - 01/00 Teresa Duncan Danielle Owen Rebecca Bahrenburg 4518 Rolo Court Mechanicsburg, PA 17055 01/00- 10/00 Teresa Duncan Chris Free Danielle Owen Rebecca Bahrenburg 4518 Rolo Court Mechanicsburg, PA 17055 10/00-01/02 Teresa Duncan Danielle Owen Rebecca Bahrenburg 4518 Rolo Court Mechanicsburg, PA 17055 01/02-07/02 Teresa Duncan Danielle Owen Teresa Duncan Chris Free Danielle Owen 4518 Rolo Court Mechanicsburg, PA 17055 5078 Pajabon Drive Harrisburg, PA 17111 07/02- 10/02 10/02 - 01/03 Tony Owen Danielle Owen 1705 Kathryn Drive New Cumberland, PA 17070 01/03 - Present 7. The mother of the child is Teresa Duncan, residing at 232 Stonehedge Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055. She is single. 2 8. The father of the child is Tony Owen, residing at 1705 Kathryn Drive, New Cumberland, Cumberland County, Pennsylvania 17070. He is single. 9. The relationship of Plaintiff to the child is that of mother. The Plaintiff currently reside with the following persons: Nanle Chris Free Paramour 10. The relationship of Defendant to the child is that of father. The Defendant currently resides with the following persons: Danielle Owen Daughter 11. From the time that the parties separated in January of 2000 until April 2003, the parties had been informally abiding by a shared custody arrangement. 12. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 13. Plaintiff has no information ora custody proceeding concerning the child pending in a court of this Commonwealth or any other state. 14. Plaintiff does not know of a 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. 3 15. The best interest and permanent welfare of the child will be served by granting the relief requested. 16. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff respectfully requests the Court to grant her primary physical custody of the minor child, Danielle Kaye Owen. In the alternative, Plaintiff respectfully requests the Court to grant her shared physical custody of the minor child, Danielle Kaye Owen. Respectfully submitted, Dated: May 29, 2003 Heather M. Faust Attorney ID #77947 Killian & Gephart 218 Pine Street Harrisburg, PA 17101 (717) 232-1851 Attorneys for Plaintiff 4 VERIFICATION I hereby verify that the statements of fact made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that any false statements therein are subject to the penalties contained in 18 Pa.C.S.A. {}4904, relating to unsworn falsification to authorities. May 28, 2003 eresa Dun~ TERESA J. DUNCAN, Plaintiff Vo TONY Q. OWEN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA .' : DOCKET NO. t93- : : CIVIL ACTION - LAW : IN CUSTODY ORDER You, Tony Q. Owen, Defendant, have been sued in court to obtain custody of the following child: Danielle Kaye Owen· You are ordered to appear in person at the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania, 17013, on the day of ., 2003, at .M., for [] a conciliation or mediation conference. [] a pretrial conference. [] a hearing before the court. If you fail to appear as provided by this order, an order for custody, partial custody or visitation may be entered against you or the Court may issue a warrant for your arrest. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. By the Court: Date: Jo TERESA J. DUNCAN, Plaintiff TONY Q. OWEN, Defendant : IN THE COLrRT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA :DOCKETNO, o3~ .~6~t ~ : : CIVIL ACTION - LAW : IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is Teresa J. Duncan, residing at 232 Stonehedge Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant is Tony Q. Owen, residing at 1705 Kathryn Street, New Cumberland, Cumberland County, Pennsylvania 17070. 3. Plaintiff seeks custody of the following child: Name Present Residence Date of Birth Danielle Kaye Owen 1705 Kathiyn Street May 26, 1997 New Cumberland, PA 17070 4. The child was bom out of wedlock. 5. The child is presently in the custody of Tony Q. Owen, Defendant herein, who resides at 1705 Kathryn Street, New Cumberland, Cumberland County, Pennsylvania 17070. 6. During the past five (5) years, the child has resided with the following persons and at the following addresses: Name Address Teresa Duncan Tony Owen Danielle Owen Rebecca Bahrenburg 4518 Rolo Court Mechanicsburg, PA 17055 Teresa Duncan Danielle Owen Rebecca Bahrenburg 4518 Rolo Court Mechanicsburg, PA 17055 Teresa Duncan Chris Free Danielle Owen Rebecca Bahrenburg 4518 Rolo Court Mechanicsburg, PA 17055 Teresa Duncan Danielle Owen Rebecca Bahrenburg 4518 Rolo Court Mecbanicsburg, PA 17055 Teresa Duncan Danielle Owen 4518 Rolo Court Mecbanicsburg, PA 17055 Teresa Duncan Chris Free Danielle Owen 5078 Pajabon Drive Harrisburg, PA 17111 Tony Owen Danielle Owen 1705 Kathryn Drive New Cumberland, PA 17070 Dates 5/26/97 - 01/00 01/00- 10/00 10/00-01/02 01/02-07/02 07/02- 10/02 10/02 - 01/03 01/03 - Present 7. The mother of the child is Teresa Duncan, residing at 232 Stonehedge Lane, Mechanicsburg, Cumberland County, Pennsylvania. 17055. She is single. 2 8. The father of the child is Tony Owen, residing at 1705 Kathryn Drive, New Cumberland, Cumberland County, Pennsylvania 17070. He is single. 9. The relationship of Plaintiff to the child is that of mother. The Plaintiff currently reside with the following persons: Name Chris Free Relationship Paramour 10. currently resides with the following persons: Name Danielle Owen The relationship of Defendant to the child is that of father. The Defendant Relationship Daughter 11. From the time that the parties separated in January of 2000 until April 2003, the parties had been informally abiding by a shared custody arrangement. 12. Plaintiff has not participated as a party or wimess, or in another capacity, in other litigation concerning the custody of the child in this or another court. 13. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. 14. Plaintiff does not know of a 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. 3 15. The best interest and permanent welfare of'the child will be served by granting the relief requested. 16. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WItEREFORE, Plaintiff respectfully requests the Court to grant her primary physical custody of the minor child, Danielle Kaye Owen. In the alternative, Plaintiff respectfully requests the Court to grant her shared physical custody of the minor child, Danielle Kaye Owen. Respectfully submitted, Dated: May 29, 2003 Heather M. Faust Attorney ID #77947 Killian & Gephart 218 Pine Street Harrisbm'g, PA 17101 (717) 232-1851 Attorneys for Plaintiff 4 VERIFICATION I hereby verify that the statements of fact made in the foregoing document are tree and correct to the best of my knowledge, information and belief. I understand that any false statements therein are subject to the penalties contained in 18 Pa.C.S.A. §4904, relating to unswom falsification to authorities. May 28, 2003 Teresa D,~~ -- TERESA J. DUNCAN PLAINTIFF V. TONY Q. OWEN DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-2541 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Wednesday, June 11, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechaniesburg, PA 17055 on Weduesday, July 09, 2003 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to al~pear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Dawn S. Sunday, Esq. Custody Conciliator q~ne Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business betbre the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO F1ND OUT WHERE YOU CAN GET LEGAL ]HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 TERESA J. DUNCAN, Plaintiff VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-2541 CIVIL ACTION LAW TONY Q. OWEN Defendant IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME Danielle Kaye Owen DATE OF BIRTH May 26, 1997 CURRENTLY IN CUSTODY OF Father / Mother 2. A Conciliation Conference was held on July 16, 2003, with the following individuals in attendance: The Mother, Teresa J. Duncan, with her counsel, Heather M. Faust, Esquire, and the Father, Tony Q. Owen, and his counsel, Bradley L. Griffie, Esquire. 3. The Mother filed a petition seeking primary physical custody of the Child as she will be beginning first grade in the Fall. Although there is no existing Order governing custody of the Child, the parties have informally been following a shared split week custody arrangement. The Child began kindergarten in the Mother's school district (Mechanicsburg) for the 2002-2003 school year but was transferred to the Father's school district (West Shore) in January due to the Mother's temporary relocation to Harrisburg as a result of the expeditious sale of her residence in Mechanicsburg. The Child finished the 2002-2003 school year at West Shore. The dispute between the parties as to choice of school district for the upcoming school year is the main complicating factor in resolving the custody issues. The parties were not able to reach an agreement at the conference and it will be necessary to schedule a heating. 4. The Mother's position on custody is as follows: The Mother believes it would be in the Child's best interest to reside primarily with the Mother and attend first grade in the Mechanicsburg school district in which the Mother resides. According to the Mother, the Child's enrollment in the West Shore school district was only a temporary measure resulting from the Mechanicsburg school district's refusal to allow the Child to continue in school in Mechanicsbnrg during the interim period from the time the Mother sold her residence in Mechanicsburg, until she moved back to Mechanicsburg with her fiancg. The Mother believes that stability is very important for the Child as she begins school on a full day basis and questions the Father's ability to provide that stability. The Mother expressed concern that the Father had been nearly evicted from his residence in New Cumberland in April (denied by Father). The Mother feels that continuing to share physical custody would not be realistic during the school year. The Mother requests primary physical custody of the Child during the school year and consent to enroll the Child in the Mechanicsbnrg school district for first grade. 5. The Father's position on custody is as follows: The Father believes it would be in the Child's best interest to reside primarily with him in New Cumberland. The Father believes that the Child should continue to attend school in the West Shore school district where she completed kindergarten in June. The Father stated that the conflict over the c, ustody arrangements arose when he was required to file for child support in order to obtain medical assistance for the Child in April. The Father disputes that there was any understanding that the Child's transfer to the West Shore school district would be temporary. The Father indicated that he has always been more involved in the Child's activities and now wishes to enroll the Child in extra-curricular activities such as cheerleading and dance classes in the New Cumberland area. The Father requests primary physical custody of the Child during the school year and consent to maintain the Child's enrollment in the West Shore school district for first grade. 6. The conciliator recommends an Order in the form as attached scheduling a heating on the primary custody and school enrollment issues and maintaining the existing arrangements pending the hearing. An expedited hearing is requested in light of the school issue involved in this matter. 7. In assigning this case to the Court for a hearing, it should be noted that it was brought to the conciliator's attention by counsel that the Mother's counsel, Heather Faust, Esquire had served as a clerk for Judge Oler several years ago. It is expected that the heating will require at least one-half day. Date Custody Conciliator TERESA J. DUNCAN, Plaintiff VS. TONY Q. OWEN Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-2541 CWIL ACTION LAW 1NCUSTODY ORDER OF COURT AND NOW, this ~ ~d ~'~ta /~ day of _ , 2003, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: scheduled in ( # S of the Cumberland County Court House, on 1 ~.A_I-Jearing is .¥u~ Room , the t~-~ dayof~,2003, at[/t/~ o'clock/~,~Forpurposesofthe Hearing, the Mother, Teresa J. Duncan, shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for the parties shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who are expected to testify at the Hearing, and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least ten (10) days prior to the Hearing date. 2. The Mother, Teresa J. Duncan, and the Father, Tony Q. Owen, shall have shared legal custo.dy of Danielle Kaye Owen, born May 26, 1997. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. Pursuant to the terms of this paragraph each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, school and medical records and information. 3. Pending further Order of Court or agreement of the parties, in every week the Mother shall have custody of the Child overnight on Mondays and Tuesdays and the Father shall have custody of the Child ovemight on Wednesdays and Thursdays. The parties shall alternate having custody of the Child on weekends, with the Father having custody on the weekend beginning July 18, 2003. The specific times for exchanges of custody under this provision shall be arranged by agreement between the parties. The parties shall equally share having custody of the Child on holidays as arranged by agreement. 4. Pending hearing and determination by the Court, the Child shall continue to be enrolled in the West Shore School District. cc.'/l~ather M. Faust, Esquire - Counsel for Mother oJ~adley L. Griffie, Esquire - Counsel for Father 0 -2q-03 SEP-03-2003 16:02 KILLIAN & GEPHART ?17 238 0592 TERESA J. DUNCAN, Plaintiff TONY Q. OWEN, Defendant : IN THE COURT OF COMMON PLE~S;OF : CUMBERLAND COUNTY~ PENNSYI~VANIA : DOCKET NO. 03-2541 : CIVIL ACTION - LAW : IN CUSTODY STIPULATION OF TIlE PARTIF.~ Entered into thc day and year hereinaf~r written by and between TeresaJ. Duncan, (hcrelnaRer referred to as "Mother"), and Tony Q. Owen, (hereinaRer retorted 1, The parties will share joint legal custody of Danielle Kaye Owen, bom ' May 26, 1997. The parties a~'ec that major decisions concerning their child, including, but not necessarily limited to, the child's health, welfare, educanon; rehgtous ~rammgi · and upbnngmg shall bc made by them jointly, after discusston and oonsultauon w~th ~ ~ch' oth~', with a v~¢w toward obtaining ~md following a harmomous policy m the chlld, s ~st intcr~t. Each pan'y asxc~ not to impair the other partf s right~ to shared legal : ca~tody of the child. Each party agr~s not to attompt to alicr~te the a£fecflo~ of the child f~om the other party. Each party shall notif~ tl~ other of any activity or ckeumstance concerning their child that could reasonably be exp¢ct~:l to he of concern to th, other. Day to day dex:i~ion~ shall ~ th~ responsibility of the p~nt then l~ing . physical custody. With regard to any emergency decisions, which mint be m~le, thc p~mt having ph~ieal ~tody of thc child at thc ~ of the ~-n~gencY. ~lllfll be .. · i ~ SEP-0~-200~ 16:0~ KILLIAN ~ GEPHART p~i~d to m~ ~y ~e~a~ &cisio~ ncc~si~t~ ~e~by. ~Howev~, t~;'P~m · sh~l ~fo~ ~e o&er of ~e em~gency ~d co~ult wi~ h~ or her~as soon ~ possible. ~ acco~ wi~ 23 Pa.C.S.A. ~ ~309, each ~ s~ be enfitl~ ~ complete and furl ~fo~ion ~ any d~tor, dentist, teach, profession~ or au~ofiW ~d to have copies of ~y ~om or info~a~on given ~o ~er p~ ~ a p~ent ~ au&ofiz~ by s~te. 2. ~ ph~ical custody of ~e ~nor child ~aH be wi~ MO&er ;~d~ ~or ch~d sh~l a~end ~e Mech~csbu~ School ~sffict. 3. Fa~ sh~ ~ve p~ ~stody of ~e nfinor c~ld'~.~cor~e w/th ~he following sc~dule: a. ~g &e school y~, Fa~ s~ll have li~ ~si~fion Wi~ &e minor c~l~ provided ~at on school ~gh~ Fa~ s~ll ret~ minor c~ld to M~ no later ~ 8:00 p.m.. b. Upon mu~ a~mt of~e pa~ies, Fa~er ~y have p~al physical custody of&e ~nor child d~ · at ~ is no s~ool f~ ~e m~or child on 4. D~ng ~e s~, &e p~i~ s~] sh~ ph~c~ c~dy of~ ~or~ c~ld ~ a~d~ce wi& &e foliow~g schedule: a. Mo&er sh~l ~ ~al ph~ic~ cu~od~ of Monday and Tuesday. 2 KILLIAN ~ F~PHART b. Father shall have partial:ph~mcal custodyof tho minor child eve,~ Wednesday and Thursday.' ' :: · c. Thc parties shall altema~ weekends. ." The parent with physical custody during any gi,~ en period of time 'shalli' coiii/ii/micate in a prompt fashion with the other parent concerning the well-being 'of: : their child, and shall appropriately notify the other parent of any changes in'h~alth 'or' educational progress. Each parent shall execute any and all legal authorizations so that the other parent may obtain information from the child's schools, physicians, psychologists, or other individuals concerning their progress and welfare. The parents shall organize ways for their child tO maimaln their :. friendships, extracurricular activities, and other special interests, regardless of Which' household they may be in. It is also suggested that toys, clothes, etc. not bccom~ mattt~,'s'. of contention. Major gifts should be discussed and coordinated between the parent~. Mother shall be primarily responsible for transporting the minor child to and from ! Brownies/Girl Scouts. Father shall b¢ primarily responsible for transporting Lhe'min0r child to and from her ballet classes. ; 7. The parents shall permit and support the child's access to all family... relationships. Special family events such as weddings, family reunions, family .: . gatherings, funerals, graduations, etc. shall be accommodated by both paffieS routine visitations resuming immediately thereafter. Each parent shall have the option of 3 SEP-0:]-2003 16:03 KILLIAN ~ GEPHRRT pm~s~g ~me or ~ v~atiom to ~e o&~ p~mt w~n sPecial ~r~al opfi°m o~ ~pe~ted oppo~ni:ies ~se, Each p~ent must confer wi~ ~e o~erPar~t' befo~ ~ging ~ly ~cu~g ex~cu~ a~ivifies for ~e ~n~ chfl~ w~cli ~ght ~t~ere'wi~ re~l~ visi~fion. 8. ~ch p~ent ~ll exercise c~ in s~g b~i~C~ld.c~ pmvid~. Each p~em shoed have the right of veto over c~ld c~e provides, ~e ~lephOne n~ or.ese provi~ wiU be provided to bo~ p~ents. P~ntS should provide one ~offi~ wi~ a phone n~ber ~ address where ~e child ~y be wh~ reasonablypo~ible, T~s p~ciple a~lies to simmiom such as vacafio~ ~d ov~gh~ wi~ ~&. Each p~ent should ~ promptly ~d po~tely res~ivg to o~ p~t's ~l~bone otis. · 9. D~ng ~y pefi~ of custody or visitation ~ p~es m ~is Or~r:s~ll ~ot p~s~s or u~ ~y con~ll~ subset, n~ shall ~ey ~e ~holic beverages to · e ~t of intoxication, nor smoke cig~ ~side ~e resid~ee or re'cie. The p~es s~l l~ewise a~e, to ~e exit possible, ~at o~ household m~be~ an~°r house ~e~ co~ly wi~ &is prohibition. 10. Each p~t s~l ~ ~till~ to ~nable ~lephone ~ntact.wi~ ~e c~ld ~ well as daily contact via e-~il wi~ ~e child when ~ ~e ,custody of~ 0~er pa~t. 11. ~h p~nt agrees n~ to a~empt to flienate ~c affections of.~e from ~e o~ ~d will m~e a ~ifl comdous effofl not to do 4 SEP-03-~003 16:0~ KILLIAN & GEPHART ?i? 238 859~ P.86/87 ~blish a n~c~fli~ zone for their c~l~n ~d ~n ~om ~i~ ~mgato~ . . co~en~ aborn ~e o~er p~t in &e p~s~ce of~e child and, to ~e cxten~ possible, ~hall not pe~t ~ ~es to m~e such ~n~ in ~ pr,:sen~ of ~e c~ld. Each p~ent sh~l sp~ resp~lly of ~e o~ wh~er il is believed the o~er ~ci~cates or not Each p~en~l fi~re shall r~fcr to ~e o~ by the appropriate role ~ s~uch as Mom, Dad, ~ gr~o~er, etc.. Each p~ent should a~ee to rc~n ~om m~aging ~e ~ld to provide r~om about &e o~ p~t. Co~cagon shoukl ~wa~ ~e place directly b~een p~ts, without us~g ~e cl~ld as ~ ~t~e~a~. ~ch p~ent should mco~ge ~ir child to ~d ~e appr~fiate holily ~s to ~= o&er p~t. 12. Mo&~ ~! cl~ ~e ~ c~ld ~ a d~ende:nt for ~ p~ses, in heu of establis~i a ~on order ~ough ~ C~rland County Domestic RSations Offi~, Fa&~ ~11 be fin~cia~y res~ible f~ &e cosi of ~y~ for the m~or child ~ Fa&er s~l be fln~nci~ly ~onsibk for fi~ p~rcent {~0%) of ~y u~eimbu~Sod medical expenses for the minor child. KILLIAN ~ GEPHART 717 ~38 05g~ P.07/07 IN WITNESS WHEREOF, the parties.have set forth th,eh' hmad and seal the day : Heather M. Faust, Bsq. Wimcss Teresa ). Du~ i Datc Date Tony Q. fiwen Date Date TOTAL P.~? TERESA J- DUNCAN, Plaintiff TONY Q. OWEN, Defendant : IN THE COURT O]? COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA i DOCKET NO. 03-2541 } CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this~ daf' of ~-' 2003, upon review and consideration of the Stipulation of the Parties, a copy of which is attached hereto, said Stipulation is hereby ADOPTED as the Order of this Court. Dislxibution: .,Ieleather M. Faust, Attorney for Plaintiff ,,,13radley L. Griffie, Attorney for Defendant