HomeMy WebLinkAbout99-00188
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CHARLES E, PETRIE
AtlTOfM!V AT lAW
3528 '
HARRISBUR~RISBAN STREET
~~ENNSYlVANIA 17111
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JAN 1 419~
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present with Defendant and Defendant's hUSband, at 4 Trine
Avenue, Mt, Hall y Springs, Pennsylvania,
The mother of the child is PAMELA PALMER SOWARD, who
currently resides at 4 Trine Avenue, Mt, Holly Springs,
Pennsylvania. She ,is mard'~d.
The father of the child is not known,
~. The relat:lonship of the Plaintiffs to the child is that
of maternal uncle and aunt. The PlaintJffs currently reside wHh
their three daughters, Sara, age 10; Erin, age 7; and Madeline,
age 2.
5. The relationship of the Defendant to the child is that
of mother, She currently resides with the child and with her
hUSband, Larry A. Soward,
6, The Plaintiffs have not participated as a party or
witness, or in another capacity, in other litigation concerning
the custody of the child in this or in another court.
The Plaintiffs have no information of a custody proceeding
concerning the custody of the child in this or in another court.
Plaintiffs do not know of a person not a party to these
proceedings who has physical custody of the child at who claims
to have custody or visitation rights with respect to the child,
7. The best interest and permanent welfare of the child
will be served by confirming rights of primary physical and legal
custody in Plaintiffs,
2, The natural. mother, PAMELA LYNN SOWARD, shall have.
liberal rights of tempora ry physical custody of the subject minor
child as the parties shull from time to time agree,
3, The parties agree tha t this Order of Court shall remain
in full force and effect at least until th8 end of the 1998-99
School year.
IN WITNESS WHEREOF, the parties have h8reunto set their
hands and seals the day and year first above written,
WITNESS------------------
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INPA~
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DAWN D. PAL~IER
WITNESS---------------
WITNES S --
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PAMELA LYNN SOWARD
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CHARLES JOHN PALMER and
DAWN D, PALMER,
Plaintiffs/Respondents
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
NO, 99-188 CIVIL TERM
PAMELA PALMER SOWARD,
Defendant/Petitioner
IN CUSTODY
CUSTOD.YMIPULATION AND AGREEMENT
THIS AGREEMENT AND STIPULA nON, entered Into the day and year hereinafter
set forth, by and between the Defendant/Petitioner, Pamela Palmer Soward, (hereinafter
referred to as "Mother") and the Plaintiffs/Respondents, Charles John Palmer and Dawn
D, Palmer, (hereinafter referred to as " Custodial Parents"),
WHEREAS, the Petitioner is the natural mother of Rachel Dawn Palmer, born
October 5, 1991, (hereinafter referred to as "Child"); and,
WHEREAS, the parties wish to enter Into an Agreement relative to the custody and
partial custody of the child; and,
NOW, THEREFORE, in consideration of the mutual covenants, promises and
agreements as hereinafter set forth, the parties agree as follows:
1, The Mother shall have primary physical custody of the child,
2, The Custodial Parents shall have partial physical custody of the child as the
parties shall agree to include partial physical custody of the child through the remainder
of the 1999/2000 school year.
3, The parties will keep each other advised immediately in the event pi serious
illness or medical emergency concerning the child and shall further take any necessaf'J
steps to ensure that the health and well being of the child is protected, During such illness
or medical emergency, both parties shall have the right to visit the child as often as he or
she desires consistent with the proper medical care of the child,
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4, Neither party shall do anything which may estrange the child from the other
party, or injure the opinion of the child as to the other party, or which may hamper the free
and natural development of the child's love or affection for the other party.
5, Any modification or waiver of any of the provisions of this Agreement shall
be effective only if made in writing and only if executed with the same formality as this
Stipulation and Agreement.
6, The parties desire that this Stipulation and Agreemont be made an Order of
Court to the Court of Common Pleas of Cumberland County, and further acknowledge that
the Court of Common Pleas of Cumberland County does, In fact have Jurisdiction over the
Issue of custody of the parties' minor child and shail retain such jurisdiction should
circumstances change and either party desire or require modification of said Order,
7, The parties agree that in making this Agreement, there has been no fraud,
concaalment, overreaching, coercion, or other unfair dealing on the part of the other,
8, The parties acknowledge that they have read and understand the provisions
of this Agreement. Each party acknowledges that the Agreement is fair and equitable and
that it is not the result of any duress or undue influence,
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IN WITNESS WHEREOF, the parties hereto intending to be legally bound by the
term, s hereof, set fort(ih th ' hands and seals the, day and year herein mentioned,
~ESS:, /'/<
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Pamela Palmer dWard
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Charles J6hn Pal e
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_Lila.!::.;} /ltl))?/. 'I'..........
Dawn 0, Palmer
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