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Home My WebLink About99-01903 ;~~ i'. .... LARRY E. WRIGHT, JR. and KATHY J. WRIGHT, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- IqD3 CIVIL TERM CIVIL ACTION--LAW CATHERINE FAHNESTOCK, Defendant CUSTODY ORDER OF COURT AND NOW, this , ~ I ~., day of Ar r I I , 1999, upon consideration of the within Custody Stipulation and Agree- ment between Larry E. Wright, Jr. and Kathy J. Wright, hereinaf- ter "Adoptive Parents," and Catherine Fahnestock, hereinafter "Natural Mother," regarding the child Kayla Ann Wright, born March 30, 1999, hereinafter "Child," it is hereby ordered as follows: 1. Adoptive Parents shall have legal custody of Child, meaning that they shall have the legal right to make major deci- sions affecting the best interest of the child and all of the major matters related to the child, including, but not limited to, medical, religious and educational decisions. 2. Adoptive Parents shall have primary physical custody of Child. 3. Natural Mother shall have partial physical custody and ~ fj c:; i'- tJ[; .. ;;- ,ct: <:) Sil ::s ~€i ~ &~ (f' r) '" ci..' -- ~"?~ CJ:!lj , .:('9) ;:!; <:c a!~ ~ ~lJ< l!5 .." ~fJtE ~ ~~ e LARRY E. WRIGHT, JR. and Y.ATHY J. WRIGHT Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- J9C>3 CIVIL TERM CIVIL ACTION--LAW v. CATHERINE FAHNESTOCK, Defendant CUSTODY Made this CUSTODY STIPULATION AND 5/5T day of /I; A~ 0/ AGREEMENT , 1999, by and between Larry E. Wright, Jr. and Kathy J. Wright, hereinafter "Adoptive Parents," and Catherine Fahnestock, hereinafter "Natu- ral Mother,"; WHEREAS Natural Mother has a child, namely Kayla Ann Wright, born March 3D, 1999, hereinafter "Child," whose father's identity is unknown; and WHEREAS, the parties wish to enter into an agreement rela- tive to custody, partial custody and visitation of the child; and WHEREAS, Child has resided in Cumberland County, Pennsylva- nia for the majority of at least six (6) months, thus giving this Court jurisdiction. NOW THEREFORE, in consideration of the mutual covenants, promises and agreements as hereinafter set forth, the parties agree as follows: 1. Adoptive Parents shall have legal custody of Child, meaning that they shall have the legal right to make major deci- sions affecting the best interest of the child and all of the major matters related to the child, including, but not limited to, medical, religious and educational decisions. 2. Adoptive Parents shall have primary physical custody of Child. 3. Natural Mother shall have partial physical custody and visitation with Child as agreed between the parties. 4. The failure to either party to insist on strict perform- ance of the provisions of this stipulation and agreement shall not be construed as a waiver of any subsequent default of the same or similar provision. 5. The parties agree and desire that this stipulation and agreement be made an Order of Court of the Court of Common Pleas of Cumberland County, Pennsylvania, which Court will retain juriSdiction should any party desire or require modification of said order. IN WITNESS WHEREOF, the parties hereto intending to be legally bound by the terms hereof, set forth their hands and seals the day and year herein set forth. WITNESS: ~tJ~ La E. r' t, Jr. /\~ 0 :?/AA-IJJ- Kathy . "Wright a Crl.J.hHlin c/ .-!r"AI1Mfrrr..J Catherine Fahnestock ~~ . ':J ~ vt " ~ 0 ~ -4-J 0 -E >- cr. Lr) .a a; ~ Q) ~ c: -f- ~2 a. ~ r<1 '" :~-r S - p,:C :z:: f ~ \lO -15 -,-Vo O~ ;!f3 "'"' 0- 00 ~ (:)2:1 sf) c::- o) UJff. ~?">- -0 ,'~.rn -J I ..:J-, '=R +i 1 ~ G:lU t:l:: m(5 iE Cl.. j <:r ~ q flla: ,.. C7'l :2 - :::l C7'l U Mark F. Bayley, Esquire BAYLEY & MANGAN 17 West South Street Carlisle, PA 17013 (717) 241-2446 Supreme Court I.D.#87663 LARRY E. WRIGHT, JR., and KATHY J. WRIGHT, Plaintiffs VS. CATHERINE FAHNESTOCK, Defendant. FILED-OFFICE OF THE PROTHONOTARY 2011 AUG 22 PM 3: 4 4 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-1903 CVIL TERM IN CUSTODY STIPULATION The undersigned parties hereby stipulate to the entry of a court order containing the following terms (the Honorable J. Wesley Oler, Jr., was previously assigned to the within matter). 1. All previous orders relating to the above docketed matter are hereby vacated. 2. Kathy J. Wright shall have sole legal custody of the minor child, Kayla Ann Wright, bom March 30, 1999. 3. Kathy J. Wright shall have primary physical custody of the child. 4. Custodial periods/visitation between the child and Larry E. Wright, Jr. or Catherine Fahnestock (N.K.A. Catherin Huff) shall be at the discretion of Kathy J. Wright. f A-dC9 -/f Lar E. Wright Date Kathy J. WA?ht Date Vt* e es tock Date N.K.A Catherin Huff CERTIFICATE OF SERVICE I, Mark F. Bayley, Esquire, do hereby certify that I this day served a copy of the foregoing document upon the following by First Class U.S. Mail: Larry E. Wright Jr. 11 Ritner Garden Shippensburg, PA 17257 Catherin Huff 122 West North Street Apt B Carlisle, PA 17013 Mar F. Bayley, Esquire LARRY E. WRIGHT, JR., and KATHY J. WRIGHT, Plaintiffs VS. CATHERINE FAHNESTOCK, : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Cl) r., c • -Q3 N0.99-1903 CVIL TERM zrn C Z;0 c? cn 'c- r- :c IN CUSTODY -< v %.J C' -?o Defendant. x 3 ORDER OF COURT 3''y -< ? AND NOW this day of v , 2011, upon stipulation by the parties it is hereby ordered as follows: c? --t mr ?m C>cv b? --tm 1. All previous orders relating to the above docketed matter are hereby vacated. 2. Kathy J. Wright shall have sole legal custody of the minor child, Kayla Ann Wright, born March 30, 1999. 3. Kathy J. Wright shall have primary physical custody of the child. 4. Custodial periods/visitation between the child and Larry E. Wright, Jr.. or Catherine Fahnestock (N.K.A. Catherin Huff) shall be at the discretion of Kathy J. Wright. cc: `Mark F. Bayley, Esquire ? aITY E. Wright, Jr. ?Catherine Fahnestock (N.K.A. Catherin Huff) 8 a? tl?g BY THE COURT: