Loading...
HomeMy WebLinkAbout01-05647IN THE COURT OF COMMON PLEAS VERSUS Shawn C. Morris, Defendant N O. No. O1 - 5647 Civil Term DECREE IN DIVORCE AND NOW, ~~'' 1 , ~, IT IS ORDERED AND DECREED THAT TammiT.Morris PLAINTIFF, AND Shawn C. MO1T1S ,DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; _ PROTHONOTARY ~ !` ,~~ ~'~li~/~ ~ ~ ~.~,. p . g i ~j G~ TAMMI T. MORRIS, Plaintiff vs. SHAWN C. MORRIS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2001 Civil Term 5647 ACTION IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under 33§ Ol(c~ of the Divorce Code. 2. Date and manner of the service of the Complaint: Delivered by certified mail, restricted delivery, return receipt requested, delivered on: ~ ~ y-~,~ , ~®~ ~ s 3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: By Plaintiff: ~ ~ ~ -3 By Defendant: S' ~ ~ , `~ 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: + _ ~ ~ 3 Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary (~ Respectfully Submitted: Date: r _ `~ , 2 3'an Adams, Esquire I.D. 0.79465 . Pitt Street Carlisle, Pa. 17013 (717)245-8508 Attorney for Plaintiff ~~~~... .; TAMMI T. MORRIS IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. • 01-5647 CIVIL ACTION LAW SHAWN C. MORRIS DEFENDANT IhI CUSTODY ORDER OF COURT AND NOW, Thursday, October 04, 2001 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. ,the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, October 31, 2001 at 9:30 AM for aPre-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 appear 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/ Jacqueline M Verne, Es~_ Custody Conciliator The 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 before the court, please contact oar 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 FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717)249-3166 ® ~. /O~h~ ~/t ~ /~~v _~ JO~i'0/ ~~~ ~ t ,,1n ~, ~asn~ra, ,, ~ ,. ~~i ;,.: _ ._ TAMMI T. MORRIS, Plaintiff vs. SHAWN C. MORRIS, Defendant s ~ ,i~~ ~~ , ,~ SEP 2g~01 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. CJ 1 ` s(o~l ~' Civil Term ACTION IN DIVORCE ORDER OF COURT AND NOW, this day of , 2001, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before ,Esquire, the conciliator, at ,Pennsylvania, on ,the day of 2001, at o'clock .m. for aPre-Heazing 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 heazd by the court, and to enter into a temporary order. Either party may bring the child who is the subject of this custody action to the conference, but the child's attendance is not mandatory. Failure to appear at the conference may provide grounds far entry of a temporary or permanent order. FOR THE COURT, Custody Conciliator 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 WIIERE YOU CAN GET LEGAL HELP. OFFICE OF THE COURT ADMINISTATOR CUMBERLAND COUNTY COURTHOUSE, 4TH FLOOR CARLISLE, PA. 17013 (717)240-6200 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 accomodations 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. TAMMI T. MORRIS, Plaintiff vs. SHAWN C. MORRIS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. ~ j ~ SL~~ Civil Term ACTION IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You aze warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment maybe entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. Where the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM THEM. 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 TAMMI T. MORRIS, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. No. (~'~ . s(o y ~ Civil Term SHAWN C. MORRIS, ACTION IN DIVORCE Defendant COMPLAINT IN DIVORCE COUNT I -DIVORCE 1. Plaintiff is Tammi T. Morris, a competent adult individual, who has resided at 1015 Yverdon Drive, Camp Hill, Cumberland County, Pennsylvania, since July 15, 2000. 2. Defendant is Shawn C. Morris, a competent adult individual, who has resided at 14 S. Front Street, Wormleysburg, Cumberland County, Pennsylvania, since August 2000. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on September 27, 1997 in Onondaga County, New York. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised that counseling is available and that plaintiff may haue the right to request that the court require the parties to participate in counseling. 7. Plaintiff and Defendant have one child together, namely, Colton C. Morris, date of birth July 29, 1998. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: (a) That the marriage is irretrievably broken; and/or (b) That the Defendant has offered such indignities to the Plaintiff, the innocent and injured spouse, as to render her condition intolerable and life burdensome. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. COUNTII-CUSTODY 1. Plaintiff is Tammi T. Morns who currently resides at 1015 Yverdon Dr., Camp Hill, Pennsylvania, 17011. 2. Defendant is Shawn C. Morris, who currently resides at 14 S. Front St., Wormleysburg, Pennsylvania. 3. Plaintiff seeks custody of the following children: NAME ADDRESS AGE Colton C. Morris 1015 Yverdon Drive, Camp Hill, Pa. 17013 3 The child was not born out of wedlock. The child is in the custody o£ Tammi T. Morris who resides at 1015 Yverdon Dr., Camp Hill, Pennslyvania, 17011. During the past five years, the child has resided with the following persons and at the following addresses: NAM ADDRESSES DATES Tamrru T. Morns 1015 Yverdon Dr. 7/00 -present Camp Hill, Pa. 17011 ~.~~, Tammi T. Morris 3090 Old Trail Road 3/99 - 7/00 Shawn C. Morris York Haven, Pa. 17370 Tammi T. Morris 2129 Kellogg Road 7/98 - 3/99 Shawn C. Morris Balwinsville, NY, 13027 The mother of the children is: Tammi T. Morris currently residing at: 1015 Yverdon Dr., Camp Hill, Pa. 17011. She is married. The father of the children is: Shawn C. Morns, currently residing at: 14 S. Front St., Wormleysburg, Pa. He is married. 4. The relationship of plaintiff to the children is that of Mother. The plaintiff currently resides alone. 5. The relationship of defendant to the children is that of Father. The persons that the defendant currently resides with are: his brother, Scott Morns. 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Plaintiff does not know of a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 7. The best interest and permanent welfaze of the children will be served by granting the relief requested because: It would be in the best interest of the child to have a custod, o~ rder which eta regular and frequent visits with father in order that all narties have a set schedule of visitation. 8. Each pazent 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 requests the court to grant custody of the children. Respectfully submitted, Date: ~ . a 7 . ©~ -- J e Adams, Esquire I . No. 79465 117 South Hanover St. Cazlisle, Pa. 17013 (717)245-8508 ATTORNEY FOR PLAINTIFF ;. w VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. ~~,n~u ~~ Tammi T. Morris, Plaintiff a~~~i .... _. ~ azdrtszm~~a_ ~rs~:~avvna~w~.;i»sasaaz~^E;:~.,a rs~~i~~'C~#Fi~ - :.~,,....~S SIT - l ... ~. -,:,.... ~:a< ... _, ,.. ~~ ~ ,7 ~ ~ ~ ~ ~ ~ ~ ~ ~= ~ o ~ -~1~~ ,v~ `il ~ ~ ` c,~ ~ Uc r~i~.. 7 CY 1 z, r ,. O ~ C ~ ~,r_ ~ ~,n ,~ ~ .~. ~ L ~= r„ _ :T, TAMMI T. MORRIS, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 2001 Civil Term 5647 SHAWN C. MORRIS, :ACTION IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on September 27, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to urisworn falsification to authorities. Date: t~ G Tammi T. Morris, Plaintiff WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DNORCE DECREE UNDER 533011c1 OF THE DIVORCE CODE 1. I consent to entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: ~ , ~ • 3 \~~ IU nn Tammi T. Morris, Plaintiff c? e,~ ~~' ~ ~ ., m~=. ,. ~, a r! c= = ~ .. rJ r'~l f~ ~E ~'~~ ~~ ~~ TAMMI T. MORRIS, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 2001 Civil Term 5647 SHAWN C. MORRIS, :ACTION IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on September 27, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: /'9~03 ~• Shawn C. Morris, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDERUNDER _ 33071c1 OF THE DIVORCE CODEOF THE DIVORCE CODE 1. I consent to entry of a final decree of divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C:S. §4904 relating to unsworn falsification to authorities. /y~/J Date: ~ ~ ~ ~ ®~ ~ /' f ~-"'_'- wn C. Morris, Defendant • i TAMMI T. MORRIS, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 2001 Civil Term 5647 SHAWN C. MORRIS, ACTION IN DIVORCE Defendant AFFIDAVIT OF SERVICE OF NOTICE TO DEFEND AND COMPLAINT AND NOW, this October 8, 2001, I, Jane Adams, Esquire, hereby certify that on October 4, 2001, a true and correct copy of the NOTICE TO DEFEND AND COMPLAINT were served, via certified mail, restricted delivery, return receipt requested, addressed to: Shawn C. Moms 14 S. Front Street Wonnleysburg, Pa. 17043 DEFENDANT Respectfully Submitted: J e Adams, Esquire I. . No. 79465 South Hanover St. Carlisle, Pa. 17013 (717)245-8508 ATTORNEY FOR PLAINTIFF 4 ._ ~i -~ r' 4 - Co ~' (.a [~ ~ T~ _ '>_ ._ -, `I ~~ 3 i .._. _V _ _ _ __ ~ C'omplete~tems 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ^ Print your name and address on the reverse so that we can return the card to you. ^ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: Q corn G~ ~'tornS 1 y Sr ~~5~: Ltbrrvr ~vh~r~ P~- /~0~13 2. Article Number (Copy /rom service label) ~ A. Receivetl by (Please Print Clearly) I B. C. Signatur X e ^ Agent J'~~. ~._ ^ Addre D. Is delivery address different from item 1? ^ Ves If YES, enter delivery adtlress below: ^ No 3. Service Type Certified Mail ^ Express Mail ^ Registered ^ Return Receipt for Merchandise ^ Insured Mail ^ C.O.D. 4. ResMCted Delivery? (Extra Fee) ~ Vas PS Forth 3811; July 1999 Domestic Return Receipt 102595-9B-hF77 d --~ ~A~ ~~ ~ 2QQ~' ~' TAMMI T. MORRIS, Plaintiff V. SHAWN C. MORRIS, Deffendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.2001-5647 CIVIL TERM CIVIL ACTION -LAW IN CUSTODY ORDER OF COURT AND NOW, this 17`"day of January, 2002, the Conciliator being notified that the parties have reconciled, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, Q f ` `~ Y r_ d ~- `"~ ~ cqu ne M. Verney, Esquire, Custody ciliator } TAMMI T. MORRIS, Plaintiff vs. SHAWN C. MORRIS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2001 Civil Term 5647 ACTION IN DIVORCE ORDER AND NOW, this a~ ~ day of i"~'"'?j , 2003, having reviewed the agreement between the parties dated October 10, 2002, it is hereby ORDERED and DECREED that the agreement shall be entered as an O: J. _~ ~. J ~ JS/!~ Cpfh,' ~,~ ~~rl~i_ ;~~; 7,7 8 +' • `, `~ 7~~' _ i. _~,. W - .. n TAMMI T. MORRIS, Plaintiff vs. SHAWN C. MORRIS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2001 Civil Term 5647 ACTION IN DIVORCE STIPULATION AND CUSTODY AGREEMENT This Stipulation and Custody Agreement is made this ~ ~~'day of ~~bW , 2002, by and between Tammi T. Morris (hereinafter referred to as "Mother"), and Shawn C. Morris (hereinafter referred to as "Father"); WITNESSETH: WHEREAS, Mother and Father are the natural parents of one (1) minor child, namely, Colton C. Morris, born July 29, 1998, and; WHEREAS, Mother and Father have reached an agreement relative to the future care, custody, and visitation of their child, the terms of which agreement both parties desire to set forth in the present Stipulation and Custody Agreement, and WHEREAS, Mother and Father desire the provisions of the present Stipulation and Custody Agreement be approved by the Honorable Court of Common Pleas of Cumberland County and entered as a Court Order, with the same force and effect as though said Order had been entered after Petition, Notice and Hearing. NOW THEREFORE, the parties, intending to be legally bound, and in consideration of the mutual promises and agreements contained herein, hereby agree as follows: 1. Leval Custody. Mother and Father shall have shared legal custody of their minor son, Colton C. Mon•is. Joint legal custody means both parents have the right to control and share in making of decisions of importance in the life of their child, including educational, medical, and religious decisions. Both parents shall be entitled to equal access to the child's school, medical, dental, and other important records. As soon as practicable after the receipt by a party, copies of the child's school schedules, special events notifications, report cards, and similar items shall be provided to the other party. Notwithstanding that both parents shall share legal custody, non-major decisions involving the child's day-to-day living shall be made by the parent then having custody, consistent with the other provisions of this Agreement. Morns. 2. Residential Custodv. Mother shall have primary physical custody of Colton C. 3. Partial Custodv. Father shall have partial physical custody of the Child as follows: a. Every other weekend fro(m5 riOd at 5:00 0' clock P.M. until Sunday at 8:00 o'clock P.M. beginning ~ ~1 1J Z b. Tuesday and Thursday Nights from 5:00 p.m. through 8:00 p.m. c. Father may keep the child overnight Thursday night through Friday Morning at 10:00 a.m. every other weekend. This additional period of custody shall occur the Thursday after his period of weekend custody. When Father keeps the child overnight, he will be responsible for dropping the child off at daycare in a timely fashion. d. Other days or evenings, including overnight visits, as agreed upon by the parties. The parties may modify times and dates by mutual agreement. d.. Vaeatiors a d tlolida s. Father shall have partial physical custody as follows: a. Two one-week periods during the summer, each increment to be no more than one week in length starting on Sunday and ending on Saturday. The parties may also agree on two-day visits during holiday breaks in the school year. Father shall be responsible for arranging and paying for any childcare charges incurred during the two weeks. These fees will be paid directly to the provider. b. Father shall have a period of custody with the child from 12:00 pm. through 8:00 p.m. on Father's Day and Mother shall have a period of custody with the child from 12:00 p.m. through 8:00 p.m. on Mother's Day. c. The parties shall alternate the following holidays: Labor Day, Memorial Day, and Fourth of July. This alternating schedule will begin on Labor Day, 2002, when Mother will have custody of the child. When Father has the child on an alternating holiday, custody shall begin at 12:00 p.m. and last through 8:00 p.m. d. Each parent shall have a period of at least three hours with the child on the child's birthday. e. The parties shall share the following holidays: Easter, Halloween, and Christmas Eve, and Christmas. On each of these Holidays, Mother shall have the child from 8:00 a.m. through 2:00 p.m. and Father shall have the child from 2:00 p.m. through 8:00 p.m. 5. Other provisions. The parties shall keep each other informed at all times as to the whereabouts of the child and an address and phone number where the child may be reached. Father shall not take the child more than 50 miles from Mother's residence without prior consent of Mother, and shall provide a telephone number and destination address before leaving for any trip. Mother shall notify Father of any trips she will make with the child and will also provide a telephone number and destination address should she take a trip with the child. Mother is permitted to modify Father's visits should she visit her relatives. If Mother chooses to modify or postpone a period of Father's custody, she will provide make-up visitation days to Father. 6. Ongoing Relationship Neither parley shall attempt to undermine the mutual love and affection that the child may have for the other parent and neither parent shall, in the present of the child, make any disparaging or negative remarks concerning the other parent. Each party shall confer with the other on all matters of importance relating to the child's health, maintenance, and education with a view toward obtaining and following a harmonious policy in the child's education and social adjustment. Each party agrees to keep the other informed of his or her residence and telephone number to facilitate communication concerning the welfare of the child and visitation period. Each party agrees to supply the name, address, and telephone numbers of any person in whose care the child will be in for a period in excess of forty-eight (48) hours, and for each person or entity which may provide daycare for the child. 7. Illness of the Child. Emergency decisions regarding the child shall be made by the parent then having custody. However, in the event of any emergency or serious illness of the child at any time, any parry then having custody of the child, shall communicate with the other party by telephone or any other means practicable, within one hour, informing the other party of the nature of the illness or emergency, so the other parent can become involving in the decision making process as soon as possible. During such illness, each party shall have the right to visit the child as often as he or she desires, consistent with the medical care of the child. 8. Welfare of the Child to be Considered. The welfare and convenience of the child shall be the prime consideration of the parties in any application of the provisions of this Agreement. 9. Binding effect. This Agreement and all of its terms and conditions shall extend to and be binding upon the parties hereto and their respective successors, executors, administrators, heirs, personal representatives, and assigns. 10. Gov ruing Law. This Agreement shall be governed and controlled by the laws of Pennsylvania. 11. Amendment. No term or provision of this Agreement may be modified or amended, except by means of a written instrument executed by the parties hereto. 12. Headines. Section and paragraph headings in this Agreement are included for the convenience of reference only and shall not constitute part of this Agreement for any other purpose. 13. Background. The background provisions to this Agreement set forth above (including, without limitation, all defined terms set forth above) are hereby incorporated in this Agreement and made a part hereof as if set forth intheir entirety in this Section. 14. EnfEnf r~ The parties. agree that this Agreement maybe adopted as an Order of Court without the necessity of a Court hearing. 15. End Agreement. This Agreement contains the entire understanding between the parties concerning the subject matter hereof, and no representations, inducements, promises or agreements, oral or otherwise, not embodied herein shall be of any force or effect. This Agreement supersedes any and all prior agreements, written or oral, between the parties hereto relating to the subject matter of this Agreement. IN WITNESS WHEREOF, the parties have hereto duly executed the present Stipulation and Custody Agreement the day and year first above written. WITNESS: ~~ ~J~SYa yi Tammi T. Morris s/ C fiZ~ Shawn C. Morris ~ ~ l COMMONWEALTH OF PENNSYLVANIA {~ ~" ~ )as COUNTY OF CRb4TdD ya aPI(GL/t~ ) On this, the a ~~~ay of ~~ r (~ ~ G( , 2002, before me, the undersigned officer, personally appeare - known to me, (or satisfactorily proven) to be the person whose name is subscn ed to the within instrument, and acknowledged that he/she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notai P blic My . otarial Seal Josepq E. Aisberry ,Notary Public SE ~~ ~~``~" Hanisburg, Dauphin County ~+ny Commission Expires Mar. 9, 2004 Member, Pennsylvania Association of Notaries COMMONWEALTH OF PENNSYLVANIA ):ss COUNTY OF ~brK ) On this, the IZT~-day of ~~ , 2002, before me, the undersigned officer, personally appeared ~ tt Ir1 ~- ~ r l01'~ ~ s known to me, (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he/she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. l~/~`~/ No Public My commission expir ots,<m~t say auk voix ~~~ ~ SEAL ,, ~xat,~ ripe n, sr~ ;r ~> C -• C.: i ~' `' ( J , c'! n.~ L,: Cj Y~~ 'C Y_. _. - x ~_ _ :~ ~_ J 'J l .~' ~ `~ C~ 4 ~,