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Home My WebLink About01-05335t t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MELANIE A. BOBBINS, NO. DL -- s3~ ~l V ~(,~~ Plaintiff/Petitioner v. CIVIL ACTION -LAW KENNETH R~ROBBINS III, Defendant/Respondent CUSTODY ORDER AND NOW, TO WIT, this ~''i~ "Ylay of ~ 2001, upon consideration pf the attached Petition for Entry of Stipulation, it is hereby C4s'rod~ A q 2.euw~e.rt- ORDERED and DECREED that the cushion datedthe / ~ ~ day of, p ~ t: etit..n.~A.r..+c ~"'` , 2001, is adopted as an Order of Court and the parties are bound thereby. BY THE C ~'^"0 ~ Judge + _..~..._..,...:~'se~-a;~aisax.:~::r:. u~.;s,:t~..w:.~:..,, sE,.s.~-.asw~i..;e~aat:,.s~tia.... .. _,. .,..: ~._ .. .. _~_:~:~.~tX~'II~~"~"' - ~ ..~ ~. ~_~: _. ~I r , ~ ~ f7 ~ ` Z ~ `~ :, ~'r-- T ~~ =~ "" Y~lJ ~~.-~ < i~ ~!'~! ~c ra ~_ •, (r ~," ~ ~ ~C, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MELANIE A. ROBBINS, NO. Cat - 53.3.5 ~l U i ~~~~ Plaintiff/Petitioner v. CIVIL ACTION -LAW KENNETH R. ROBBINS III, Defendant/Respondent CUSTODY PETITION FOR ENTRY OF STIPULATION 1. The Plaintiff/Petitioner is Melanie A. Robbins, an adult individual who resides at 503 E. Elmwood Avenue, Apartment #2, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. The Defendant/Respondent is Kenneth R. Robbins III, an adult individual who resides at 605 South Spring, Carlisle, Cumberland County, Pennsylvania, 17013. 3. The parties are the natural parents of son, Corey D. Robbins, date of birth: October 2, 1996. 4. On ,LI , 2001, the parties entered into a stipulation regarding custody, partial custody and visitation of the child, which is attached hereto and incorporated herein as Exhibit "A." 5. The best interest of the child will be served by the Court's entering said custody stipulation as set forth as Exhibit "A" as an Order of Court. WI-IEREFORE, Plaintiff/Petitioner requests this Court to approve the foregoing stipulation and make it an Order of Court. DATED: ~ <<f GS/ Respectfully submitted, ,~ ~~," atrick O'Connor, Esquire 3105 Old Gettysburg Road Camp Hill, Pennsylvania 17011 Telephone: 717-737-7760 I.D. No. 64720 Attorney for Petitioner/Defendant EXHIBIT "A" CUSTODY AGREEMENT THIS AGREEMENT made and entered into this ~~~ day of ~, 2001, by and between MELANIE A. ROBBINS, of Cumberland County, Pennsylvania, (hereinafter known as "Mother") PARTY OF THE FIRST PART, and KENNETH R. ROBBINS III, of Cumberland County, Pennsylvania, (hereinafter known as "Father"), PARTY OF THE SECOND PART. WHEREAS, Mother and Father are desirous of providing for the shared custody of their minor child, Corey D. Robbins, born October 2, 1996, (hereafter known as "Child"); and NOW, THEREFORE, THIS AGREEMENT WITNESSETH that for and in consideration of the promises and covenants herein contained and intended to be legally bound hereby, it is agreed by and between the parties hereto as follows: 1. CUSTODY AND VISITATION A. Mother and Father shall have joint legal custody of the parties' minor Child to the end that the parties shall share jointly the custodial responsibility for the minor Child. By custodial responsibility, the parties shall share major decisions concerning education, medical care, and spiritual upbringing. The parties hereby expressly agree and state that it is not possible nor desirable to dissolve the parental relationship between the parties either as to the minor Child or as to themselves. Therefore, the parties expressly state and agree that a~ they wish to continue to be jointly, as well as severally, responsible for the custody and upbringing of their Child. B. The parties hereby designate Mother to be primary physical custodian of said Child, subject to the rights of partial custody in the Father, as stated below. As a result of such designation, Mother alone shall have the right and duty to make all day-to-day parental decisions and act as the primary care parent to the Child. Therefore, Mother may, on her signature alone, authorize emergency medical care for the minor Child, authorize absences and special events for said Child in school, and authorize the physician, dentist or other medical person to care for said Child. C. During the period of time when Mother is the primary physical custodian, Father shall have visitation as follows: [a] Every other weekend, visitation with the Father shall commence on Sunday at 12:00 noon. On alternating weekends, visitation shall commence on Saturday at 9:00 a.m. At the end of each weekend, visitation shall conclude on Monday mornings at the time that school starts. However, in the event that the Child will not be going to school for any reason, visitation with the Father shall continue unti14:30 p.m. on Monday. In the event that school is in session on any Monday, but the Child cannot attend school for any reason, Father shall so notify Mother prior to 9:00 a.m. on Monday. [b] Father shall have partial custody on the following schedule: Visitation for holidays, including Christmas, as well as vacations, shall be determined by mutual agreement. Father shall have custody on each Father's Day and Mother shall have custody on each Mother's Day, regardless of any other provisions of this agreement. The Father shall have visitation any other times as the parties shall mutually agree. [c] Both Mother and Father realize that it will be desirable from time to time to alter the weekend schedule set forth above in order to accommodate special circumstances, for example, family gatherings. Mother and Father are willing to adjust his or her schedule, within reason, to accommodate the plans of the other. Under such circumstances, it is expected that time will be "traded- ofP' so that the total hours of weekend visitation will remain approximately the same as contemplated by subparagraph [a], above. [d] In the event that Father shall take the Child outside of Pennsylvania, Father agrees to provide advance notice, and to provide a telephone number where the Child can be reached, if possible. [e] In the event that the Child should develop any physical injury or ailment during visitation, Father agrees to contact the Mother immediately. 2. LEGAL COUNSEL The Mother is represented by the law office of G. Patrick O'Connor, Esquire. The Father has been advised of his right to seek legal counsel of his choice. Each of the parties agrees that he or she has entered into this Agreement with a complete understanding of the contents thereof. 3. ORDER OF THE COURT The parties agree that this Agreement shall be entered as an Order of Court and shall continue in full force and effect until [a] further Order of Court, or [b] stipulation of the parties. 4. ADDITIONAL INSTRUMENTS Each of the parties shall from time to time, at the request of the other, execute, acknowledge, and deliver to the other any and all further instruments that maybe reasonably required to give full force and effect to the provisions of this Agreement. 5. APPLICABLE LAW The parties agree that, regardless of the child's residence or provisions of the Uniform Child Custody Jurisdiction Act, Pennsylvania shall retain jurisdiction over the custody of the minor Child as long as one or both parents reside with the Commonwealth. 6. BINDING EFFECT _ ~~;~ This Agreement shall be binding upon the respective parties, their heirs, executors, administrators, successors and assigns. 7. ENTIRE AGREEMENT This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements or negotiations between them. IN WITNESS THEREOF, the parties have hereunto set their hands and seals on the day and year first above written. ~ ~ f~~~ , (SEAL) .~z---~~~ (SEAL) ME ANIE A. BOBBINS KENNETH R. BOBBINS III COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND SS. On this, the ~ 1 day of ~, 2001, before me, a Notary Public in and for the state and county aforesaid, the undersigned officer, personally appeared MELANIE A. ROBBINS, known to me (or satisfactorily proven) to be the person described in the foregoing instrument, and acknowledged that he executed the same for the purposes therein contained. WHEREOF, I hereunto set my hand and official seal. ~ (SEAL) Not Public Notarial Seai Tsresa ;t. Syv~rfer, Notary Public Fairvievr ;v~t~., York Coun OF PENNSYLVANIA) My Commiss'son laxpiros Mac t , 2048 SS. p~aoer,Pamsylvan PssocfeUOnof otare® COUNTY OF CUMBERLAND On this, the L l day of lJ~ ~ n I , 2001, before me, a Notary Public in and for the state and county aforesaid, the undersigned officer, personally appeared KENNETH R. ROBBINS III, known to me (or satisfactorily proven) to be the person described in the foregoing instrument, and acknowledged that she executed the same for the purposes therein contained. 1N WITNESS WHEREOF, I hereunto set my hand and official seal. (SEAL) Notary Public Notarial Ssal 'l'ertsa A. Svroyer, Notary ping Pa3rvlea~ 7wpp., YarY, Ctyutity My Commission E'xpiros Mar. 9 , doe Mer.'lbor,PermsylvaniapssoeiBHOn~ Ptotarlaq ~.... _, : `' 3Pk5' iac~:3:a s*. m.~.s~~.-a.ue 4m>=-.sakt~,:t _ ~... ...... - (l f ''~ k ~ ~~. rn 7 '_)~~'3 ~ ~ ~ _•' -~