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HomeMy WebLinkAbout99-03673Mm ,M 4 t Q 3 1 vm A o- ji? % W" i i 1 v i i i By The Co Attest: J. GLk/???. Prothonotary ,• IN THE COURT OF COMMON PLEAS I OF CUMBERLAND COUNTY STATE OF PENNA. TEDRA G. ALLEMAN Plaintiff Versus CRAIG D. ALLEMAN ... Defendant \().,99.71673.,, Civil•..Term DECREE IN DIVORCE AND NOW, .....'N'. . .......... MgPP! it is ordered and decreed that ....... , ,TEDRA G. ALLEMAN Plaintiff, and .................. CRAIG D. ALLEMAN 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 0 been entered; MARRIAGE SETTLEMENT AGREEMENT IS INCORPORATED BUT NOT MERGED .................................................... . . ................. r'i; y , A 8 TEDRA G. ALLEMAN, Plaintiff V. CRAIG D. ALLEMAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3673 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE ov and aeo?o? a '29 - and Sec a S. C 4&may, ' (' o- e -ga&olld'ra a3?+ a? in,?,?n c,? '2001 TABLES OF CONTENTS Parties to Live Separate and Apart ...................................................... 2 Personal Property .......................................................................... 2 Marital Debts ............................................................................... 2 Real Property ............................................................................... 3 Alimony and Support for Self ............................................................ 3 Waiver of Interest in Retirement ........................................................ 4 Legal Representation ...................................................................... 4 Mutual Discharge .......................................................................... 4 No-Fault Divorce .......................................................................... 5 Execution and Delivery of Documents ................................................. 6 Breaching Party Pays Costs .............................................................. 6 General Provisions .........................................................................6 opo- /? and Cfoxo? Cqu? THIS AGREEMENT, made this ;3 766ay of !2 A. 2001, by and between CRAIG D. ALLEMAN, hereinafter referred to as "Hus and", and TEDRA G. ALLEMAN, hereinafter referred tc as "Wife". WHEREAS, the parties hereto are Husband and Wife, having been married on October 7, 1995; and WHEREAS, differences have arisen between Husband and Wife, as a result of which it is the desire of the parties after long and careful consideration, amicably to adjust, compromise and settle all property rights and all rights in, to, or against each other's property or estate, including property heretofore or subsequently acquired by either party, and to settle all disputes existing between them, including any and all claims for maintenance, support, alimony, equitable distribution, counsel fees, and costs; and WHEREAS, it is the mutual desire of Husband and Wife to reduce their agreement to writing; and NOW, THEREFORE, in consideration of the mutual promises, covenants, and agreements hereinafter contained, each of the parties hereto, intending to be legally bound i hereby promises, covenants, and agrees as follows: 1. PARTIES TO LIVE SEPARATE AND APART The parties mutually agree to live separate and apart. Neither party will molest the other, or in any way harass or malign the other, nor in any way interfere with the peaceful existence of the other. 2. PERSONAL PROPERTY Husband and Wife have divided all personal property, which would constitute marital property. Wife agrees that any property in the possession and control of Husband shall be the sole and separate property of Husband. Husband agrees that all property in the possession and control of Wife shall be the sole and separate property of Wife. Each of the parties does hereby specifically waive, release, renounce and forever abandon whatever claims, if any, he or she may have to the sole and separate property of the other. 3. MARITAL DEBTS Husband and Wife each covenant, represent, and agree that each other will now and at all times hereafter save harmless and keep the other indemnified from all debts, charges, and 2 A liabilities incurred by the other prior to or after the effective date of this Agreement, except as may be otherwise specifically provided for the by the terms of this Agreement. 4. REAL PROPERTY Husband and Wife acknowledge that they are fee simple owners of two parcels of property located at 1135 Three Square Hollow Road, Newburg, PA 17240, situated in Hopewell Township, Cumberland County, Pennsylvania, and that in consideration of $14,000.00 the Wife will waive and relinquish any interest in the property and agrees to sign the necessary Deeds to transfer her interest to the Husband. Wife acknowledges that she has already received $4,000.00 from Husband and that the amount due her is $10,000.00. (Copies of Deeds attached as "Exhibit A and B") 5. ALIMONY AND SUPPORT FOR SELF Both parties acknowledge and agree that the provisions of this Agreement providing for equitable distribution of marital property is fair, adequate and satisfactory to them and is accepted by them in lieu of and in full and final settlement and satisfaction of any claims or demands that either may now or hereafter have against the other for support, maintenance or alimony. Husband and Wife further, voluntarily and intelligently, waive and relinquish any right to seek from the other any payment for support or alimony. Each party shall indemnify, 3 A defend and hold the other harmless against any future action for either support or alimony brought by or on behalf of the other, such indemnity to include the actual counsel fees of the Wife in any such future action. 6. WAIVER of INTEREST IN RETIREMENT Husband and Wife expressly waive and relinquish any right, claim, title or interest in any pension, profit-sharing, retirement, credit union or employment-related plans in which the other has any interest, whether vested or unvested, matured or unmatured. 7. LEGAL REPRESENTATION Husband and Wife declare that each has had a full and fair opportunity to obtain and consult with legal counsel of his/her selection and that the parties, cognizant of their legal rights, declare and express that: A) Austin F. Grogan, Esquire, represents Craig D. Alleman; and B) Robert L. O'Brien, Esquire, represents Tedra G. Alleman. 8. MUTUAL DISCHARGE Wife relinquishes her inchoate intestate right in the estate of Husband, and Husband 4 relinquishes his inchoate intestate right in the estate of Wife, and each of the parties hereto for himself or herself, his or her heirs, executors, administrators or assigns does remise, release, quitclaim and forever discharge the other party hereto, his or her heirs, executors, administrators or assigns, or any of them, of any and all claims, demands, damages, actions, causes of action or suits of law or inequity of whatsoever kind or nature for or because of a matter or thing done, omitted or suffered to be done by said party prior to and including the date hereof, except that this release shall in no way exonerate or discharge either party hereto from the obligations and promises made and imposed by reason of this Agreement. 9. NO-FAULT DIVORCE An action for Divorce has been instituted by the Wife in the Court of Common Pleas of Cumberland County, Pennsylvania, docketed to No. 99-3673 Civil Term alleging that the marriage is irretrievably broken and requesting a no-fault divorce under Section 3301(c) of the Divorce Code. It is hereby agreed that the marriage is irretrievably broken and that coincident to the signing of this Agreement, both parties will execute affidavits of consent to the entry of a Decree in Divorce under Section 3301(c) of the Divorce Code. 5 10. EXECUTION AND DELIVERY OF DOCUMENTS The parties hereto agree to execute and deliver all papers needed to effectuate the terms and intentions of this Agreement. 11. BREACHING PARTY PAYS COSTS If either party breaches any provisions of this Agreement, the other party shall have the right, at his or her election, either to sue for specific performance or for damages for such breach, and the party breaching this Agreement shall be responsible for reasonable legal fees and costs incurred by the other in enforcing his or her rights under this Agreement. 12. GENERAL PROVISIONS This Agreement encompasses all agreements between the parties concerning the matters set forth herein and may not be altered or omitted except in writing executed by the parties; the waiver of any term, condition or provision of this Agreement shall in no way be deemed a waiver of any other term, conditions or provisions of this Agreement. If any term, condition or provision of this Agreement shall be determined to be void or invalid in law or otherwise, then only that term, condition or provision shall be stricken from 6 this Agreement, and in all other respects, this Agreement shall be valid and continue in full force. It is agreed by and between the parties hereto that this Agreement shall survive and shall not be merged into any decree, judgment, or order of divorce or separation. It is specifically agreed, however, that a copy of this Agreement or the substance of the provisions thereof, may be incorporated, by reference, into any divorce, judgment, or decree. This incorporation, however, shall not be regarded as a merger, it being the specific intent of the parties to permit this Agreement to survive any judgment and to be forever binding and conclusive upon the parties. This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. This Agreement is executed in triplicate, and Husband and Wife, as parties hereto, acknowledge the receipt of a duly executed copy hereof. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the date first above written. 7 1 A!. AL- Cra' D. Alleman, Defendant Tedra G. Alleman, Plaintiff 7 COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND On this, the day of ?2LCLZ,LL 2001, before me, the undersigned officer, personally appeared CRAIG D. ALLAN., known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and notaries seal. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS On this, the,2?3"6Cday of Jt_ (T2_ur1 t- 2001, before me, the undersigned officer, personally appeared TEDRA G. ALLE?AN known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and notaries seal. .?ruC? , ccC NOTARY ?- Notarial Seal (((/// a,onda D. Rudy, Notary Public imp Hill Boro, Cumberland Cou :rmmisslon Expires Aug. 12,2& 2 -nsYNan Association of Notaries N W ,. o ? F w N W 7 O ? is •.i ct O W v. w u •.. a W .. w c: ? n.? o p` ? ??? U >• E t7 Q .-l rp 2H w G; O U <F, • i '? v • W Z H Q f+. ?% rt L' ? r c '' O H W W L a S ? Z E' U fz U 2 O ?] : ?7 a C W 3 ? ? 3 a C p p rl HW i- 2 F H W Uy y?U C L 1? EU d?] U FL ? ? U !r, ? E F a O L C] rL W C ? W a? '. .7 O H 7 W C. H U 2 U H C-F U TEDRA G. ALLEMAN, Plaintiff V. CRAIG D. ALLEMAN, Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3673 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD Transmit the record, together with the following information, to the court for entry of a divorce decree; Code1. Grounds for divorce: irretrievable breakdown under §3301(c) of the Divorce . 2. Date and manner of service of the complaint: By Acceptance of Service on June 24, 1999. r 3. Date of execution of the Affidavit of Consent required by § 3301(c) of the Divorce Code: by Plaintiff February 23, 2001; by Defendant February 23, 2001. 4. Related claims pending: NONE 5. Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: February 27, 2001. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: February 27, 2001. 6. Plaintiffs Social Security number is 179-64-1862. Defendant's Social Security number is 164-68-9675. Respectfully submitted, Date Austin F. Grogan, Esquo 24 North 32nd Street Camp Hill, Pennsylvania 17011 (717) 737-1956 Attorney for Defendant ID #59020 AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND I, Austin F. Grogan, Esquire, hereby certify that I did mail a true and correct copy of the Praecipe to Transmit the Record in the above-captioned matter to: Robert L. O'Brien, Esq. O'Brien, Baric & Scherer 17 W. South Street Carlisle, PA 17013 which satisfied the requirements of service by mail pursuant to Pa. R.C.P. 403. I understand that false statements are made herein are made subject to the penalties of Pa.C.S. § 4904, relating to unworn falsification to authorities. Date AJ? Austin F. Grog#,, E quire 24 North 32nd Street Camp Hill, Pennsylvania 17011 (717) 737-1956 Attorney for Defendant ID #59020 vi m t a 0 a G. 41 J-1 W y. ru CG S z •~ \S C Ft a J= 'C} F 4 C- Is) C: C H „ - F .w CJ U? L z r. Z It u.z 0.7 H I a `. n. F O `?JM= O U 4] IrJ 3 Z= n rl, .^- A r H w Q .{ U O z a C L) W U 2 r'r U a 0 a 0 C7 q ti W C Q. U :C W O+ a H .>; C7 [-rc Hp a H •r p O H T w rx G' I-• U z U I-. F U TEDRA G. ALLEMAN Plaintiff V. CRAIG D. ALLEMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- 3(073 CIVIL TERM CIVIL ACTION-LAW 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 are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be 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. When 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 in the Office of the Prothonotary at the Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 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, PA 17013 Telephone: (717) 249-3166 TEDRA G. ALLEMAN Plaintiff V. CRAIG D. ALLEMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.99- 8G73 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE COMPLAINT UNDER SECTIONS 3301(C) AND 3301(D) OF THE DIVORCE CODE 1. Plaintiff is Tedra G. Alleman, an adult individual who currently resides at 22 Lurgan Avenue, Shippensburg, Franklin County, Pennsylvania. 2. Defendant is Craig D. Alleman, an adult individual who currently resides 1135 Three Square Hollow Road, Newburg, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 7, 1995 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised of the availability of counseling and that she may have the right to request that the court require the parties to participate in Counseling. 8. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, the Plaintiff requests the court to enter a decree of divorce in favor of the Plaintiff and against the Defendant. Respectfully submitted, O'BRIEN, BARIC & SCHERER Robert L. O'Brien, Esquire I. D.# 28351 17 West South Street Carlisle, PA 17013 (717) 249-6873 Attorney for Plaintiff, Tedra G. Alleman 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. Tedra G. Alleman Date: 442 r r• r Y v n w ?Ie G? v 2 m a w a , zz z z z ? n o a a W w W x W U W < O 2 a W N a G F U y ? Z UO'? 2a a„y .y a? a ro a'O as H? V w > i w U F, c? z C? ro Q w L) S m i ' 5 03 W a x H Cl 0, z rn v?° W a ° m < W 0 E U O E- E O z H n ? d y ?4 TEDRA G. ALLEMAN, Plaintiff V. CRAIG D. ALLEMAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3673 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE AFFIDAVIT OF ACCEPTANCE OF SERVICE I, CRAIG D. ALLEMAN, Defendant in the above-captioned action in Divorce, hereby acknowledge that I have in fact received a copy of the Complaint for Divorce in this matter on June 24, 1999 at 9:OOAM. 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 unworn falsification to authorities. Date: June 24, 1999 CRAIG D. ALLEMAN ., to a w pl, 0 U `c 3 a w W a? ? O Q W N N a f., E- ra 2+ p w .. ? U) _ U N H .Z . (C • W H r4 V) E+ :? a 2 H T C; . O 6 u ce v ? af_ ? ? aG :cw G o??=? ° z x ? Er u r? z a a w a E E" U C. O ! kc V H w ry E+ , E- U U u' ? U fY W `t ?? rt C C9 G U ) wa m :. u xw -- aH a u a F W HG a i. U O U ? W FS v TEDRA G. ALLEMAN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 99-3673 CIVIL TERM CRAIG D. ALLEMAN, CIVIL ACTION-LAW Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 17, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of 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 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities. Date TEDRA G. ALLEMAN co Q w F, W Jj 4 w Oa w ti F ? a w F v o O s N F U U >, a Q ro a °?oa E" H r] c a Q H E O OD 0 U 1 Y < F H U Z W Pi w 3 Z ;> Q 5 p 1- H w Q rt O ?`+ V U r U r? Q , r U P. w a o Q> c? a w w w Ft FP: tip 5 o `r in Q V H J w a. H U 7 L) F U TEDRA G. ALLEMAN, Plaintiff V. CRAIG D. ALLEMAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3673 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(4 OF THE DIVORCE CODE 1. I consent to the 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: 7 J' 6)I J'/?C?(Q `1CJ n ?k'X/?l(?st` TEDRA G. ALLEMAN ,a L 44 G W ?. P. W y 21 E.. U > a Q • rc . w ?'J 21. Q O.. ? ? .4. F U ,y U Q ri U R: a o a> U ° ~ W b:w rn aH Q G E, n4 a .? > Q H U U F U TEDRA G. ALLEMAN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 99-3673 CIVIL TERM CRAIG D. ALLEMAN, CIVIL ACTION-LAW Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 17, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of 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 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unworn falsification to authorities. Date CRAIb D. ALLEMAN I' k a z w + W z w r. v7 C rS R+ •.+ N 'I. G. W .N 'U O .. C N 3 C •ti C o: U `o ? ? ` R U >• t] rt N ?l + w W , vi Wz ? z FC G. > eLp O?m1? O p I-+ I T. `- E ? O E. r U W W f< 3 ?l Z c . . j N f? rl O ?] I] n: U p G h N W r1 r„ G 0 2 N U U ?7 I 2 O (^ p G, ? W Q. Cn 9 •i x W O. i-] H ? O p Q zo o .z w a U TEDRA G. ALLEMAN, Plaintiff V. CRAIG D. ALLEMAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3673 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 330I(c) OF THE DIVORCE CODE 1. I consent to the 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. 7 ? 6 ?{ Date: CRAIG D. ALLEMAN W a a Z r V C (J o rL w N tt H rL w c i. F O C 1 44 " v a E+ wz H > a 2 1 ¢a. 7 0. cR o o 0M Iti I w w o U r; Z nr c- u Z a a W C, o a a c- a? D U P r H w ct a; H O2 LL? NU T U .2 m U w ? a F O U P W a `r w CC W P• a H K i(9 P+ H R P: ?+ > A M 7.. U O H G W M Iti U 7 U H F U w TEDRA G. ALLEMAN Plaintiff V. CRAIG D. ALLEMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- J(, _?3 CIVIL TERM CIVIL ACTION-LAW 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 are 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. When 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 in the Office of the Prothonotary at the Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 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. Court Administrator Cumberland County Court House Fourth Floor Carlisle, PA 17013 Telephone: (717) 240-6200 TEDRA G. ALLEMAN Plaintiff V. CRAIG D. ALLEMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- 3(.7-3 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE AMENDED COMPLAINT UNDER SECTIONS 3301(A)• 3301(C) AND 3301(D) OF THE DIVORCE CODE 1. Plaintiff, TEDRA G. ALLEMAN, filed a divorce action to the above term and number on June 17, 1999 alleging the irretrievable breakdown of the marriage. Defendant, Craig D. Alleman, accepted service of the Divorce Complaint on June 17, 1999. 2. The aforementioned Complaint of Divorce is hereby amended to the following counts as grounds for divorce. COUNTI 3. The averments contained in the Complaint filed for divorce on June 17, 1999 are incorporated herein by reference. 4. Plaintiff avers in the alternative that Defendant, in violation of his marriage vows and the Laws of the Commonwealth of Pennsylvania, has offered such indignities to the person of the Plaintiff, her injured and innocent spouse, as to render the condition of the Plaintiff intolerable and life burdensome. 5. Plaintiff avers that Defendant has committed adultry. COUNT 11-DIVISION OF PROPERTY 6. Plaintiff hereby incorporated by reference all of the averments contained in Count I. The parties have acquired personal property and real estate during the course of their marriage located as follows: 1135 Three Springs Square Hollow Road, Newburg, PA COUNT III-PAYMENT OF FEES 8. Plaintiff requests alimony, alimony pendente lite, costs and counsel fees. WHEREFORE, the Plaintiff requests the court to enter a decree of divorce in favor of the Plaintiff and against the Defendant. Respectfully submitted, O'BRIEN, BARIC & SCHERER By ?L tiR3,%- Robert L. OVien, Esquire Attorney for Plaintiff I. D. # 28351 17 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 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. TEDRA G. ALLEMAN J 7 ?e t' n P.v M 7 a d 'J a il n L z o u? p H ? 2 ? 'y J r U ? Z 9 Q ? Z z a cu _ z ? m ? Q H 84 TEDRA G. ALLEMAN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA 3e•,73 V. NO. 99.373-CIVIL TERM CRAIG D. ALLEMAN, CIVIL ACTION -LAW Defendant IN DIVORCE ORDER OF COURT AND NOW, this "day of ?Y16% ,2000, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before the conciliator, at on the "';?. ,'11 day of 2000, at for a Pre-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 in to a temporary order. Either party may bring the child/children who is/are the subject of the custody action to the conference, but the child's/children's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. For the Court, I 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 WHERE YOU CAN GET LEGAL HELP. OFFICE OF THE COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE, FOURTH FLOOR CARLISLE, PENNSYLVANIA 17013 TELEPHONE NUMBER: (717) 240-6200 0D .':'?! I 1c. : r;: 211 CUs,--• , ,: TEDRA G. ALLEMAN, Plaintiff V. CRAIG D. ALLEMAN, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-373 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE ANSWER WITH NEW MATTER AND NOW, this 11" day of January, 2000, the Defendant, Craig D. Alleman, by and through his Attorney, Austin F. Grogan, Esquire, avers the following: 1. No answer is required; 2. No answer is required; 3. No answer is required; 4. Denied. Strict proof is demanded; 5. Denied. Strict proof is demanded: 6. No answer required; 7. Admitted. The parties have acquired marital property. However, the parties entered into a comprehensive settlement agreement and the Plaintiff waived any interest in the marital home; 8. No answer required; NEW MATTER - CUSTODY 9. The parties are the natural parents of two children, Halee Rose Alleman, born December 9, 1992, and Alex Hannah Alleman, born March 29, 1995; 10. The children were born out of wedlock; 11. The children are currently in the custody of the Plaintiff; 12. During the past five years, the children have resided with the following persons and at the following addresses Tedra Alleman 22 Lurgan Avenue July 1999 to present Shippensburg, PA 17257 Craig and Tedra Alleman 1135 Three Square Hollow Road December 1994 to July 1999 Newburg, PA 17240 13. The relationship of Plaintiff to the child is that of natural mother. 14. The relationship of Defendant to the child is that of natural father. 15. Defendant has not participated as a party or witness, or ir, another capacity, in other litigation concerning the custody of the child in this or another court. 16. Defendant has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 17. Defendant does not know of a person not a parry to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 18. The Defendant seeks primary custody for the following reasons: a. Each parent is equally fit to raise the children; b. The parties have not been able to agree as to what is in the best interest of the children as it relates to custody 19. Each parent 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, the Defendant, Craig Alleman, respectfully requests this Court to schedule a Custody Conference to identify the issues and resolve the custody dispute. Respectfully submitted, stin F. Grogan, Es ' e Attorney for Plainti 24 North 32°' Street Camp Hill, PA 17011 (717) 737-1956 ID # 59020 VERIFICATION I, CRAIG D. ALLEMAN, verify that the statements made in the foregoing Answer with New Matter are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unswom falsification to authorities. Date -2600 ? L CRAI D. ALLEMAN e•\ \ ?+• \? \ \?' V \ Q a a w J w E N a a 41 W F M Q ?$ 0 O N ur ? a •ro as •a ao w z ? ?: = ° °¢ wz H > ? _ r 0.7 > 1 x' O= O U fy U Z (y W a F H 3 n 9 a E ^. a O a _ w V l L7 a M H W Q Q 0 z E- C.) " a QO U O 3 x W O a H Q H F CO A C Q > HU Z UH F U TEDRA G. ALLEMAN, ) IN THE COURT OF COMMON PLEAS Plaintiff ) OF CUMBERLAND COUNTY, PENNSYLVANIA VS. ) NO. 99-3673 CIVIL TERM CRAIG D. ALLEMAN, ) Defendant ) CIVIL ACTION - LAW ORDER AND NOW, this day of_ -jr,r t 2000, upon receipt of the Conciliator's Report, it appearing that the parties have reached an agreement, which was dictated in their presence and approved by them and their counsel, it is hereby ordered and directed as follows: 1. The parties shall share legal custody of their minor children, I lalee Rose, d.o.b. December 9, 1992, and Alex I lannah, d.o.b. March 29, 1995. 2. Mother shall have primary physical custody of the minor children subject to periods of partial custody and visitation with Father as follows: A. On alternating weekends from Friday after school or after daycare until Monday morning at which time Father shall return the children to school or the appropriate daycare provider. This alternating weekend schedule shall continence on Friday, March 31. 2000. B. One evening per week front ;titer school or daycare until the liillowing morning at which time Father shall return the _ ,,. Jl children to school or the appropriate daycare provider. The parties shall agree which day this period of custody shall occur each week. 3. Father shall have the children on Father's Day and Mother shall have the children on Mother's Day, at times to be agreed upon. 4. The parties agree that they shall share all holidays, at times to he agreed upon. 5. Each party is entitled to two non-consecutive uninterrupted weeks of vacation with the children throughout the year. The parties shall provide each other with thirty (30) days advance notice as to when they intend to exercise these periods of exclusive custody. 6. Such other times as the parties may agree. Robert L. O'Brien, Esquire Austin F. Grogan, Esquire mlb BY THE COURT, /-, fl ' ?p 1`? TEDRA G. ALLEMAN, ) IN THE COURT OF COMMON PLEAS Plaintiff ) OF CUMBERLAND COUNTY, PENNSYLVANIA VS. ) NO. 99-3673 CIVIL TERM CRAIG D. ALLEMAN, ) Defendant ) CIVIL ACTION-LAW JUDGE PREVIOUSLY ASSIGNED: None. CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the child(ren) who is(are) the subject of this litigation is as follows: NAME BIRTHDATE CURRENTLY IN CUSTODY OF Halee Rose Alleman December 9, 1992 Alex Hannah Alleman March 29, 1995 2. A Conciliation Conference was held on March 30, 2000, and the following individuals were present: the Plaintiff and her attorney, Robert L. O'Brien, Esquire; the Defendant appeared with his attorney, Austin F. Grogan, Esquire. 3. Items resolved by agreement: See attached Order. 4. Issues yet to be resolved: See attached Order. 5. The Plaintiff's position on custody is as follows: See attached Order. 6. The Defendant's position on custody is as follows: See attached Order. 7. Need for separate counsel to represent child(ren): Neither party requested. 8. Need for independent psychological evaluation or counseling: None requested and the Conciliator does not believe any is necessary. Date: April 12, 2000 ln3?I v?-=-"?-- I Michael L. Bangs Custody Conciliator TEDRA G. ALLEMAN Plaintiff V. CRAIG D. ALLEMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3673 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE NOTICE OF ELECTION TO RETAKE PRIOR NAME Notice is hereby given that the Plaintiff in the above matter, having been granted a Final Decree in Divorce from the Bonds of Matrimony on the 14th day of March, 2001, hereby elects to retake and hereafter use her prior name of Tedra G. Motter, and gives this written notice avowing her intention in accordance with the provisions of the Act of May 25, 1939, P.L. 192 (23 P.S. 98), as amended. Dated: .? o19-nl y i4Q `ICJ o Qua-laic- Tedra G. Alleman TO BE KNOWN AS \ ICCL? ?((1 ? /?? h Q i?l, Tedra G. Motter COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. ti On the 19 day of M ?CZac-k 2001, before me, a notary public, personally appeared Tedra G. Motter to be known as, known to me to be the person whose name is subscribed to the within document, and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. Notenai Seal Mgale F Unggar Notary Audio Carlisle Saco, Cumbedaad County MY Commisabn Explna OCt. ? =ppq Maroeq pa'areYNana Aaaoaetbn W Notsry? U) ?' ?L U' ?? ? " [ ? ..? ? ? ? ' "V . ^ ? '? > . . ._. - ?\ _. .) i ` ` ? •?J MARIA P. COGNETTI & ASSOCIATES MARIA P. COGNETTI, ESQUIRE Attorney I.D. No. 27914 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Email: mcognetti@cognettilaw.com ~> a ~ ~~ ~`, Attorneys for Defendant/Petirioner TEDRA G. ALLEMAN, IN THE COURT OF COMMON PLEAS Plaintiff/Respondent :CUMBERLAND COUNTY, PENNSYLVANIA v. N0.99-3673 CRAIG D. ALLEMAN, :CIVIL -ACTION -LAW Defendant/Petitioner IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY ORDER 1. Petitioner is Craig D. Alleman, who currently resides at 1141 Three Square Hollow Road, Newburg, PA 17240. 2. Respondent is Tedra G. Shope f/k/a Tedra G. Alleman, who currently resides at 12093 Forge Hill Road, Orrstown, PA 17244. 3. The parties are the natural parents of two minor children, namely, Halee Rose Alleman, born December 9, 1992 and Alex Hannah Alleman, born March 29, 1995. 4. Pursuant to an Order of Court, dated April 14, 2000, the parties share legal custody of the two children, Respondent has primary physical custody and Petitioner has regular periods of partial physical custody, according to a specified schedule. Said Order of Court is attached hereto and marked as Exhibit "A." 5. The parties altered the terms of their custody arrangement approximately four years prior to the filing of this Petition. 6. Petitioner currently exercises his custodial right to physical custody of the minor children, every other weekend during the school year from after school on Friday unti19:00 p.m. on Sunday night and every Tuesday from after school until 9:00 p.m. During the summer, ~ 70.00 P A AT1-/ ~~- yt~VB r~ a~l5~~5 Petitioner exercises his custodial right to physical custody of the minor children every other week with the exchange of custody occurring Friday evenings around 8:00 p.m. 7. Petitioner seeks modification of the April 14, 2000, Order so that he may have primary physical custody of the parties' two (2) children. 8. Petitioner believes and therefore avers that it is in the best interest of the children for him to have primary physical custody for the following reasons: a. Petitioner is an equally fit parent and is equally available to the children. b. Petitioner is desirous of having the children live with him on a primary basis. c. Petitioner can better provide a familial setting that would serve the minor children's best interest. d. The children have expressed a strong desire for Petitioner to have primary custody. e. The children's best interest would be better served if they lived with Petitioner on a primary basis. 9. Petitioner believes and therefore avers that it is in the children's best interest that he be awarded primary physical custody. WHEREFORE, Petitioner respectfully requests this Honorable Court grant him primary physical and shared legal custody of the minor children. Respectfully submitted, MARIA P. COGNETTI & ASSOCIATES Date: July 21, 2010 By: /'~l~J'~ v~/ ~-- MARIA P. O TTI, ESQUIRE Attorney I.D. N 914 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorney for Defendant/Petitioner CERTIFICATE OF SERVICE I, Maria P. Cognetti, Esquire, hereby certify that I served a true and correct copy of the foregoing Petition for Modification of Custody Order at the address indicated below: Tedra G. Shope 12093 Forge Hill Road Orrstown, PA 17244 Service bv• Personal service via hand delivery X Service by First Class, United States Mail, postage pre-paid, mailed at Camp Hill, Pennsylvania, addressed as indicated above Overnight delivery Facsimile service Certified/Registered Mail Date: July 21, 2010 By: MARIA P. COGNETTI & ASSOCIATES MARIA P~/COG~TI, ESQUIRE Attorney I.D. No. 14 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorney for Defendant/Petitioner Io ~• TEDRA G. ALLEMAN PLAINTIFF V. GRAIG D. ALLEMAN DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 1999-3673 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, July 29, 2010 ,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 Monday, August 30, 2010 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. 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/ ac ueline 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 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. 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. ~-' ~ v nn__ __,, Cumberland County Bar Association c 7• ~ • ~ ~ t~'T'•• "•"C~` (Y1Q.i ~C~ '~ 32 South Bedford Street '~ t~• Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~ 7-~ 9• l © N ati ea., rna;.l esl ..4.0 ~,e~-4-• - , i v, ? • ~9 • l O C lace ~} ~ n V:er 's -~ I-c . ~ c~ ~ ~~ r~, 'U r' T11` a.-.. ,2010 AUCr 13 ?M 1= 4T {{, , hj,j TEDRA G. ALLEMAN, : IN THE COURT OF COMMON PLEAS Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99-3673 CRAIG D. ALLEMAN, CIVIL ACTION - LAW Defendant/Petitioner IN CUSTODY AFFIDAVIT OF ACCEPTANCE OF SERVICE I, Bradley L. Griffie, Esquire, do hereby accept service of a true and correct copy of the Petition for Modification of Custody Order and Order of Court scheduling a Pre-Hearing Conference directed to my client, Tedra G. Alleman, Plaintiff in the above-captioned matter, and certify that I am authorized to do so. Dated: r-J s I ( D ESQUIRE b L. Po343,49 eGRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 Telephone No.: (717) 243-5551 TEDRA G. SHOPE (ALLEMAN), IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION -LAW c-~ CRAIG D. ALLEMAN, N0.99-3673 CIVIL TERM _,.,,:~_= Defendant IN CUSTODY ~ ~' _T f _ ~=- PRAECIPE ~ 3 TO THE PROTHONOTARY: ~ ,~. Based upon the remarriage of the Plaintiff in this matter, Tedra G.. A1Fetnan~ please make note of the change in her name to her current name of Tedra G. Shope. DATE: ~(~, ~ l ~ riffle, Esquire GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 u AUG 3 0 201~~ TEDRA G. ALLEMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNS AN~1 cn V. : N0.1999-3673 CIVIL ACTION - L~',o ~ g, CRAIG D. ALLEMAN, ;~; ...~ Defendant : IN CUSTODY '{ ~ _ ~ :• ORDER OF COURT AND NOW, this 1,0~' day of , 2010, upon consideration of the attached Custody Concil ation Report, it is ordered and directed as follows: 1. A Hearing is schedyled in Co Room No. ~, of the Cumberland County Court House, on the /GZZ77 day of , 2010, at !0 ~ O~ o'clock, ~. M., at which time testimony will be taken. For purposes of this Hearing, the Father shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the Hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least five days prior to the Hearing date. 2. Pending further Order of Court or agreement of the parties, the prior Order of Court dated April 14, 2000 shall remain in full force and effect. 3. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, - p/~ Kevin .Hess, P.J. cc: Maria P. Cognetti, Esquire, counsel for Fa er ./Bradley L. Crriffie, Esquire, counsel for Mother °~ ~~~.~1 Q f ~ ~~~ ~~ TEDRA G. ALLEMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 1999-3673 CIVIL ACTION - LAW CRAIG D. ALLEMAN, Defendant : IN CUSTODY PRIOR JUDGE: Kevin A. Hess, P.J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Halee Rose Alleman December 9, 1992 Mother Alex Hannah Alleman March 29, 1995 Mother 2. A Conciliation Conference was held August 30, 2010 with the following individuals in attendance: The Father, Craig D. Alleman, with his counsel, Maria P. Cognetti, Esquire and the Mother, Tedra G. Alleman, with her counsel, Bradley L. Griffie, Esquire. 3. The Honorable Kevin A. Hess, P.J. previously entered an Order of Court dated April 14, 2000 providing for shared legal custody, Mother having primary physical custody during the school year, Father having alternating weekends and the parties having week on/week off during the summer. 4. Father's position on custody is as follows: Father seeks shared legal and primary physical custody, with Mother having alternating weekends during the school year and week on/week off during the summer. Father asserts that the children want to live primarily with Father. 5. Mother's position on custody is as follows: Mother seeks to maintain the status quo. Mother maintains that the children want to continue to reside with her and attend the same schools that they have attended for the past several years. Mother also asserts that Father has filed for modification because his child support obligation was increased recently. 6. The Conciliator recommends an Order in the form as attached scheduling a Hearing and maintaining the status quo. It is expected that the Hearing will require one day. 8 30-?0 ?j?l, f' Date cqu me M. VerneY, Es uire q Custody Conciliator TEDRA SHOPE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYWANIA rW ^. ? - VS. NO. 99-3673 CRAIG D. ALLEMAN IN CUSTODY - en cp r Defendant CIVIL ACTION - LAW CUSTODY STIPULATION AND AGREEMENT ? THIS STIPULATION AND AGREEMENT entered into the day and year hereinafter-get forth, by and between Tedra G. Shope, (hereinafter referred to as "Mother") and Craig D. Alleman, (hereinafter referred to as "Father") WHEREAS, the parties are the natural parent of two children, namely Halee Rose Alleman, born December 9, 1992, and Alex Hannah Alleman, born March 29, 1995, (hereinafter referred to jointly as "Children," or individually as "Halee" and "Alex"); WHEREAS, the parties are subject to an Order of Court dated April 14, 2000, which they wish to vacate in favor of the Order to be entered pursuant to this stipulation; WHEREAS, the parties live separate and apart, and wish to enter into a comprehensive stipulation and agreement relative to physical and legal custody of their Children; NOW THEREFORE, in consideration of mutual covenants, promises and agreements as hereinafter set forth, the parties stipulate and agree as follows: 1. The parties acknowledge that Halee is turning 18 years of age and will not be subject to the terms of this Stipulation effective December 9, 2010. 2. The parties shall have shared legal and physical custody of the children. 3. The periods of physical custody shall be shared by the parties alternating physical custody on a week-on week-off basis with exchanges of custody taking place at the end of school each Friday, or 6:00 p.m. if Alex does not have school. 4. The parties shall alternate custody on Thanksgiving such that Mother shall have custody of Alex on Thanksgiving in 2010 and all even numbered years and Father shall have custody of Alex on Thanksgiving 2011 and all odd numbered years. 5. The parties shall alternate custody on Easter Sunday such that Father shall have custody of Alex on Easter 2011 and all odd numbered years and Mother shall have custody of Alex on Easter 2012 and all even numbered years. 6. The parties shall share custody over the Christmas season by Mother having custody of Alex from noon on December 24th until 10:00 p.m. December 24th, Father having custody of Alex from 10:00 p.m. on December 24th until 3:00 p.m. one December 25th and Mother having custody from 3:00 p.m. on December 25th until 6:00 p.m. on December 26th each year. 7. A16x shall always be with Mother on Mother's Day and with Father on Father's Day. 8. For summer vacation, each party may exercise two weeks of vacation each year which shall be exercised during their week of custody, and during which the other party shall not exercise their Wednesday night period of custody. Thirty (30) days written notice shall be provided to the other party of the intention to exercise a vacation, providing the other party with the location of the vacation and contact information for the vacation location. Neither party shall remove Alex from school for vacation without the other party's consent. 9. The non-custodial parents shall be entitled to reasonable telephone contact with Alex at all times. 10. The parties shall share responsibility for transporting Alex during custody exchanges by the party delivering custody to the other party providing the transportation to the other party's residence unless otherwise agreed. 11. The parties shall keep each other advised in the event of serious illness or medical emergency concerning Alex and shall further take any necessary steps to ensure that the health and well-being of Alex is protected. During such illness or medical emergency, both parties shall have the right to visit Alex as often as he or she desires consistent with the proper medical care of Alex. 12. Neither parent shall do anything which may estrange Alex from the other party, injure the opinion of Alex as to the other party, or which may hamper the free and natural development of Alex's love and affection for the other party. 13. Any modification or waiver of any of the provisions of this Agreement on a permanent basis shall be effective only if made in writing and only if executed with the same formality as this Stipulation and Agreement. 14. 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. 15. The parties stipulate that in making this Agreement, there has been no fraud, concealment, overreaching, coercion, or other unfair dealing on the part of the other party. 16. It is affirmed that the parties are consenting to the Court of Common Pleas of Cumberland County, Pennsylvania, retaining jurisdiction over the issue of custody of Alex at this time so that it is appropriate for the Court to enter an Order of Court. Further, the parties request that the Court of Common Pleas of Cumberland County, Pennsylvania, enter this Stipulation and Agreement as an Order of Court, vacating the prior Order in effect in this matter. 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 hereinafter mentioned. WITNESSETH: Bradley L. Griffie, Esquire Date ?? A a_l!.' jiy? TEDRA G. SHOPE ?a /1. 3 v ?<A Maria P. og , tt Esquire Dad C G D. ALLEMAN COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SS. On this, the I ff day of NCe'rll ?. C , 2010, before me the undersigned officer, personally appeared TEDRA G. SHOPE, known to me (or satisfactorily proven) to be the person whose name is subscribed to the foregoing instrument and acknowledge that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notary blic NOfARNL fEAL ICIRLrtPUR INolmy FWft C*AUU9010WKCiMNR AND MY COWA NMIM &PON Jon $. 291 a COMMONWEALTH OF PENNSYLVANIA: : SS. COUNTY OF CUMBERLAND On this, the 3 day of _ e IYl Qr? 2010, before me the undersigned officer, personally appeared CRAIG D. ALLEAL N, known to me (or satisfactorily proven) to be the person whose name is subscribed to the foregoing instrument and acknowledge that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Not Public NWEALTH OF PENNSYLVANIA M A. SRFHEDF IC Nootary Public out ? 1Wrp. Cumberland Co. mhelon Ern, May t6, 2014 TEDRA SHOPE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 99-3673 CRAIG D. ALLEMAN IN CUSTODY Defendant CIVIL ACTION - LAW ORDER OF COURT AND NOW this !G , day of 7? _, 2010, the attached Custody Stipulation and Agreement is hereby made an Order of Court and all prior Orders are vacated. radley L. Griffie, Esquire Attorney for Plaintiff ---'Maria P. Cognetti,' Esquire Attorney for Defendant `-OP I' C-E rV2 t t;c(- ? C f ?l fTi c-) ["?'7 rn - ? ?- "'a C!) r - m p C7 > Cn --4m :r Q -n Y Q . - ? an D? - ?M By the Court,