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Home My WebLink About01-05071~, I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TRACEY E. GROVE CIVIL ACTION -LAW Plaintiff, vs. NO. DI° ~~ I ANDREW J. CARL Defendant. IN CUSTODY ORDER OF COURT NOW, ,, re ~ ~ , 2001, upon consideration of the within Stipulation and Agreement, it is hereby ordered s follows: Tracey E. Grove ("PlaintifF') and Andrew J. Cazl ("Defendant") shall have shared legal custody of the child, Kye E. Cleaver, born March 28, 1995. 2. Tracey E. Grove shall have primary physical custody of Kye E. Cleaver and Andrew J Carl shall have partial custody as follows: a. Friday, August 24, 2001, beginning at 6:00 P.M. and ending on Sunday, August 26, 2001, at 6:00 P.M. and similazly every other weekend thereafter. b. Christmas morning from 12:00 P.M. and continuing until New Year's Day at 6:00 P.M. c. Two nonconsecutive weeks during the summer vacation period (June 1 through August 15) with specific weeks and times of pick up and return to be agreed upon by the parties no later than May 1 of each year. d. At such other times as the parties may mutually agree. e. Plaintiff will deliver said child to the Defendant for the beginning of periods of partial custody and Defendant shall return the child to Plaintiff at the conclusion thereof. 3. The parties shall cooperate in arranging for a sharing of custody on major holidays. 4. The costs of this proceeding have been paid by the Plaintiff, Tracey E. Grove. By the Court, -'~ '~~ J. WEIGLE, PERKINS & ASSOCIATES -ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17267-1397 ~' F, =.~~: ~~ ~ _ _ , ~~ ti; .. ,,; : ~ ~ ~~ . . .. 3. `~ ~ Y`^y ~ 4 f ~ V E y^~ -~ p P{9~THi Zt :ra:~ '~..i'iG:v+fdEtSiv~fr'.4P~~~Y"!XfrSC.:.}GiR'AA9~~X6S%4S i*P. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TRACEY E. GROVE Plaintiff, CIVIL ACTION -LAW ~s. N®• ~, ~ -.~'b7l ANDREW J. CARL Defendant. IN CUSTODY STIPULATION AND AGREEMENT This Stipulation and Agreement is made this day of , 2001, by and between Tracey E. Grove of 505 Meadow Drive, Shippensburg, Pennsylvania 17257, (hereinafter referred to as "Plaintiff') and Andrew J. Cazl of 120 Abbotts Drive, Abbottstown, Pennsylvania 17301, (hereinafter referred to as "Defendant"). 1. Tracey E. Grove and Andrew J. Cazl are the natural parents of Kye E. Cleaver, born March 28, 1995, hereinafter referred to as "the child". 2. Tracey E. Grove and Andrew J. Cazl were not married at the time of the birth of the child. 3. The child is presently in the care and custody of the Plaintiff and has been since birth. 4. Neither of the parties knows of any person not a party to the proceeding who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 5. The child has resided with the Plaintiff since birth at various locations within Cumberland and Franklin Counties in Pennsylvania. 6. The parties have reached an agreement with regard to the custody of this child and desire to reduce their agreement to an Order of Court. 7. No prior Order of Court has been entered in any jurisdiction with respect to the custody of this child. 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: WEIGLE, PERKINS 6c ASSOCIATES -ATTORNEYS AT LAW - 126 EAST KING STREET - SRIPPENSRURG. PA 17259-1397 ORDER OF COURT NOW, 2001, upon consideration of the within Stipulation and Agreement, it is hereby ordered as follows: 1. Tracey E. Grove ("Plaintiff') and Andrew J. Carl {"Defendant") shall have shared legal custody of the child, Kye E. Cleaner, born March 28, 1995. 2. Tracey E. Grove shall have primary physical custody of Kye E. Cleaver and Andrew J Carl shall have partial custody as follows: a. Friday, August 24, 2001, beginning at 6:00 P.M. and ending on Sunday, August 26, 2001, at 6:00 P.M. and similazly every other weekend thereafter. b. Christmas morning from 12:00 P.M. and continuing until New Yeaz's Day at 6:00 P.M. c. Two nonconsecutive weeks during the summer vacation period (June 1 through August 15) with specific weeks and times of pick up and return to be agreed upon by the parties no later than May 1 of each year. d. At such other times as the parties may mutually agree. e. Plaintiff will deliver said child to the Defendant for the beginning of periods of partial custody and Defendant shall return the child to Plaintiff at the conclusion thereof. 3. The parties shall cooperate in arranging for a sharing of custody on major holidays. 4. The costs of this proceeding have been paid by the Plaintiff, Tracey E. Grove. 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. WEIGLE, PERKINS & ASSOCIATES -ATTORNEYS AT LAW - 126 EAST KING STREET - sHIPPENSBURG, PA 19254-139] IN WITNESS WHEREOF, the parties, intending to be bound by the terms and conditions of this agreement, execute this Agreement by signing below.. r 2 TRACEY ROVE A A~bREW J. CAR~- 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: g- a ~/- 0 ~ TRA EY E. O E 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 4404 relating to falsification to authorities. Dated: ~ ~ ~-fir ~~~ . ~~~ ANDREW J. C~ ~ T- WEIGLE. PERKINS & ASSOCIATES -ATTORNEYS AT LAW - 126 EAST KING STREET'- 6HIPPENSBURG, PA 17267-Y39] c, ,_. - r __ -H- ~. i ~ t ~ .p - :~. =- A ~.._ c" ~e " ~`` ~~a V~ 1~- \~ c.n ri f~