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Home My WebLink About01-07033 ',""~"-- Edgar Freed/12.13.01. Custody Order . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EDGAR A. FREED, JR, Plaintiff O 1- 7o:s::& NO. CIVIL TERM V. CIVIL ACTION - LAW IN CUSTODY KELLY M. FREED, Defendant CUSTODY ORDER AND NOW, this I V" day of December, 2001, upon consideration of the within Custody Agreement dated September 26, 1995, Kelly M. Freed ("Mother") and Edgar A. Freed, Jr. ("Father") pertaining to their minor children: Erica C. Freed, born September 28, 1984 and Kelsey A. Freed, born January 11, 1988 ("the Children), IT IS HEREBY ORDERED AND DECREED that the terms of the within Stipulation are incorporated by reference hereto and are hereby entered as an Order of Court. BY THE COURT~ ~ J. Distribution to: DIANE G. RADCLIFF, ESQUIRE EDGAR A. FREED, JR. KELLY M. FREED 3448 TRINDLE ROAD, 105 E. COLUMBIA DR. PERRY MANOR CAMP HILL, PA 17011 ENOLA, PA 17025 111 FROG HOLLOW RD ATTORNEY FOR EDGAR A. FREED, JR. NEWPORT, PA 17074 PRO SE "~'1:!FI.fc"'1' IJP.. '_ _ ;1"1.-, .~, p~"", r -,~ ""- ,- 'I""~ .- .~~1l'_~ -","' , -", "~'''~'~,n'',...,..""."~,,,_, ""lIl1ilii~]lilfiirTr'.'" ..... ~ -... i- S.? ti tJ --< ~' ~ '!-.? ~~ ~~ ~ ~~ ~f ~ \) ) ~ ~ L., ,~'.,"" ,. ,._i~~tl!~!tt__ ''"t'" __'_,';:: "1~ _, ~~,__~~_,,__,,~M~,_ T', '= 'c<'~' , '" '''"'~1,_,'Y' ".~ ~1","~':f1'!'T?,~.\,~~",,~~1'r,'1;";"'i~r J"3([.,11'&".<i!.("} ~'OC-_: n.r',-- ~. Y.C~ 2; =<: o ~:;:: .:;.' c..,' i::J --" ~:~') --" ", ~ ;"":1 :Al ['oO "j{f.'ffT~'@lWiii~'!'!"!$1;fi.J~1IWU~~~_~~;f. Edgar Freed/12.13.01. Custody Order IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EDGAR A. FREED, JR, plaintiff No.()1-1D~~IVIL TERM V. CIVIL ACTION - LAW IN CUSTODY KELLY M. FREED, Defendant AND NOW, this 14th day of December, 2001, Diane G. Radcliff, Esquire, Attorney for Edgar A. Freed, Jr., Plaintiff, hereby moves this Honorable Court to enter the terms of the parties' Custody Agreement dated September, 25, 1999 as an order of court, the entry of said order being authorized by the terms of that agreement. Respectfully submitted, \ tANE G. RAnC FF, ES~ i ( 3 Trindle Ro d CHill, PA 011 Phone: (717) 737-0100 Fax: (717) 975-0695 Supreme Court ID # 32112 Attorney for Plaintiff - 2 - >Vw:"i\"'1#';ff.;\!\'l~1!!mIll)~W~,; , _ ~~ I"~ -, - ""'~, b,.\_..~~~ ,., .f~-'-r-"\,i,.:,,\: ~ // AND NOW, this CERTIFICATE OF SERVICE fi--1-h day of ~c 0 .2..,...,....2001, I, DIANE G. RADCLIFF, ESQUIRE, hereby certify that I have this day served a copy of the foregoing document upon the following named person, by mailing same by first class mail, postage prepaid, addressed as follows: Kelly M. Freed Perry Manor 111 Frog Hollow Road Newport, PA 17074 Edgar A. Freed 105 E. Columbia Dr. Enola, PA 17025 Respectfully submitted, \\- E CLIF, SQUIRE 448 Trindle Road Ca , PA 17011 Phone: (717) 73 7 - 0100 Fax: (717) 975-0697 Supreme Court ID # 32112 - 3 - ';l'*'-~~)i;t. . ',' '_c' '''t:1''-~~ '!~__' ~"," ,- .- . ". 1" ,~-' " ~ '" ~ DIANE G. RADCLIFF ATTORNEY-AT-LAW 3448 TRlNDLE ROAD CAMP HILI., PA 1701I ,"",;o;~~- c".Jl'\"O ~.';" ,_~ '''1-- CUSTODY AGREEMENT THIS AGREEMENT made thi~~ay Of~ 1995, by and between EDGAR A. FREED, JR. of Enola, Pennsylvania (hereafter referred to as "Father") and KELLY M. FREED of Newport, Pennsylvania (hereafter referred to as "Mother"), the parties agree as follows with respect to ERICA C. FREED, born September 28,1984; KELSEY A. FREED born January 11, 1988; and TIFFANY A. POPP born March 13, 1982, (hereafter referred to as "Children'~: 1. PHYSICAL CUSTODY: (a) Father shall have primary physical custody of the Children and Mother shall have partial physical custody of the Children at such times as the parties shall mutually agree. (b) Absent such mutual agreement, the following schedule of partial custody of Erica C. Freed and Kelsey A. Freed with Mother shall apply: (1) Alternating weekends commencing on Friday at 6:00 p.m. until Sunday at 6:00 p.m. (2) From 9:00 a.m. until 6:00 p.m. on alternating major holidays including Easter Day, Memorial Day, Independence Day, 1 '7' , _ "C: c f~ ~. 1 " , ,~ H, _~..~ " "'~,~.. _ ~,""""~_~_~--"-1'f Labor Day, Thanksgiving Day, Christmas Eve Day and Christmas Day. ~,. :, (3) Two non-consecutive weeks of vacation time for each party upon thirty (30) days advance notice to the other party. (c) Absent mutual agreement, Mother shall have partial custody of Tiffany A. Popp at such times as Tiffany shall desire. 2. MISCELLANEOUS: (a) The aforementioned holiday scbedule shall take precedence over any other custodial period and shall not be interrupted thereby. (b) The aforementioned two week vacation periods shall take precedence over any other custodial period excepting holidays and shall not be interrupted thereby. (c) Upon mutual agreement the parties may expand or alter these custodial arrangements as may be in the best interest of the Children. (d) Each party shall have reasonable telephone access with the Children and the Children shall be permitted free access to place or receive telephone calls to or from either parent if they desires. (e) If either parent desires to relocate and establish a residence more than 100 miles from their current residence, he or she shall give the DIANE G. RADCLIFF ATTORNEY-AT-LAW 3448 TRINnLE ROAD CAMP HILL, PA 17011 other party at least 60 days advance written notice of his or her proposed 2 '-I"V.",lW~~, .,. _1!Ji_Jl,~Wi' -I'" , - ~ ~- - "~ -.- <-"'l_ ~..~~l'iI__'1'!iIl~i'P~:C__~~'-'-_~'O~_~"!'_":":"":"".!:I:_:::-':: DIANE G. RADCLIFF ATTORNEY-AT-LAW 11448 TRINllU: ROAD CAMP HILL. PA 17011 ',("'';-"~~"!,m_ l' relocation, in order to give the parties an opportunity to confer prior to such relocation and to establish a mutually satisfactory arrangement as to custody and partial custody in light of such relocation. In the event the parties are unable to reach a mutually agreeable arrangement, then either party shall have the right to petition a court of competent jurisdiction to enter an appropriate custody/partial custody order. (1) This Stipulation may be entered as an order of court in any court'of competent jurisdiction at the request of either party. IN WITNESS WHEREOF, the parties, intending to be legally bound hereby, have hereunto set their hands and seals thi~p-thday of .s..pt~ ml re f: 1995. WITNESS: ~L~ Polll^,- ~\&- ~:).\QQ^ ~ 1 ? ~I -- (SEAL) ED R A. FREED, JR. ~m.fiAM.dJ(SEALI KE LY M. REED ,,!ill', ,<_,_ . = _ 3 '" - . ~~"~_. ,. - "..._<"_ .......">~"," _-.'W! IIIlH ~", 'i~ ~W ~C0 _.....t:: ~ ~ Vr () ff! ~ .-~ . .~<- - n c <c CB~r ~~::- r:-; ~F: .:-~ r-' '----- _~_."~~_O >~, -~- ~-""";"," '~<"'-[f':'-- "'.~; -< c '~::::J " .---) :".) (D ("'~) ~ -,< '-c . , .", ,.".,"..-1-. ~m~_I~,",_~<;,,,,,^__ __,___,~?, )l1i~#~,,<;~~,,'<;r~~~')W~o~_,,:[";:,",,;i,"'_1P_,~.~!,_;i,*..n\40l\i~~\1~f~'WF~""'~i,t1'TI{'-ffh'K~i:W;\",[!if]W~~;~i1i!l~!~iP,Ii;~~;,;: