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HomeMy WebLinkAbout99-02892 !(... 1. 1:. . Y / i [! iZ. ?.. MICHAEL BROWN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. CIVIL ACTION -LAW NO. 99- dS9L CIVIL TERM JESSICA HILL Defendant IN CUSTODY ORDER OF COURT AND NOW, this day of_, 1999 it is decreed that the Stipulation and Agreement for Custody and Partial Custody that has been executed by the parties named above shall be made an Order of this Court. The Court of Common Pleas of Cumberland County shall maintain jurisdiction in this matter. BY THE C J. cc: James J. Kayer, Esquire Attorney f o r Plaintiff CC5 I z s r`Y7 3 l I F C L tAA1AF Jessica Hill, pro se U ?''I ?? ?;: . lY ??'.. n ?;?i ?.%;1V?'i? ' MICHAEL BROWN V. JESSICA HILL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW NO. 99- a Sy z CIVIL TERM Defendant : IN CUSTODY STIPULATION AND AGREEMENT FOR CUSTODY AND PARTIAL CUSTODY COMES NOW, JESSICA HILL, representing herself, pro se and MICHAEL BROWN, by and through his attorney, JAMES J. KAYER, Esquire, who do Stipulate and Agree upon the following: 1. JESSICA HILL and MICHAEL BROWN are the natural parents of one minor child, KERA ROSE THORNE, born MAY H, 1990. 2. The parties shall share legal custody of the minor child, KERA ROSE THORNE. 3. Primary and physical custody of the minor child, Kera Rose Thorne, shall be placed in the father, MICHAEL BROWN. 4. The mother, JESISCA HILL, shall have certain rights of partial physical custody of the minor child. Mother shall have the child every other weekend commencing on Fridays until the following Sundays at dates and times as the parties may mutually agree. She shall have the minor, child on alternating weekends thereafter from Friday until Sunday. 5. Mother shall have partial physical custody of the minor child on alternating holidays beginning with Labor Day, 1999. The holidays to be alternated shall include Memorial Day, Labor Day, and Thanksgiving. 6. For Christmas, the parties shall alternate A and B segments, with segment A commencing on the evening of December 24ih and concluding at approximately noon on December 25, and segment B commencing approximately at noon on December 25 until noon on December 26. The mother shall have segment A for 1999. 7. For Easter, the parties shall alternate A and B segments, with segment A commencing on the evening before Easter Sunday and concluding at approximately noon on Easter Sunday and segment B commencing approximately at noon on Easter Sunday until noon on the day after Easter Sunday. The mother shall have segment A for 2000. 8. The parties shall share custody of the minor child on each birthday with the mother having partial physical custody from after school until 8:00 p.m. 9. Mother shall have one weekday evening per week with the child, from after school until 8:00 P.M., so long as she provides the father with 24 hours notice of her intention to exercise such weekday evening visitation. 10. The summer shall be divided into two (2) segments five (5) weeks long. Segment A shall ?;nmmence the Fiid.r - Immediately following the school year's completion and shall o ,.i:;uc for a period of five (5) weeks. Segment B shall occur immediately thereafter. In odd numbered years, mother shall enjoy custody during segment A of the summer and father shall enjoy custody during segment B of the summer. Parties will alternate this arrangement from year to year. During each segment, the non-custodial parent shall have a right to exercise a visitation weekend on alternating weekends, in essence maintaining the same alternating weekends schedule establishing the school year. It is the intention of the parties in this matter for the father to enjoy at least two (2) weekends during mother's five (5) week block of time during the summer and for the mother to enjoy at least two (2) weekends during the father's five(5) week block during the summer. I I. Mother shall have partial physical custody of the minor child at other times this may be mutually agreed upon between the parties. 12. Father shall not unreasonably withhold rights of visitation or temporary physical custody. 13. The parties agree to share the responsibility for transportation arrangements to and from partial physical custody. 14. The parties understand and agree that this agreement shall serve as a general guideline as to the division of custodial rights. They agree and understand that they may modify the terms of this agreement at any time. 15. The parties agree and anticipate that this Agreement for Custody and Visitation may be entered as an Order of Court of the Court of Common Pleas of Cumberland County of "rennsyivania. 16. The parties do hereby do Stipulate and Agree that they waive their perspective rights to be present in Court at the time an order is made pursuant to this Agreement for Custody and Visitation. IN WITNESS WHEREOF, the parties hereto and each of them have hereunto set their hands and seals intending to be legally bound hereby this J?t4j- day of _ At K 1999. JESS CA HILL MICHAEL BROWN Witness Fs; ! t7?. i. t- r y ?rox ro K a w Kayer and Brown A Professional CorporationY 13 1999 Liberty Lott • 4 E. Liberty Avenue • Carlisle, PA 17013 r-.7) 243-7922