The URL can be used to link to this page

Home My WebLink About03-3119 DALE A. DUPPSTADT, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. OJ - ..1/11 SHELLEY I. DUPPSTADT, DEFENDANT 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 is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Court Administrator's Office, Fourth floor, Cumberland County Courthouse, Hanover and High Streets, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 ~ NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(c) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. DALE A. DUPPSTADT, PLAINTIFF IN THE COURT OF COMMON PLEAS ctlMBERLAND COUNTY, PENNSYLVANIA v. NO. 03- jll<i SHELLEY I. DUPPSTADT, DEFENDANT IN DIVORCE COMPLAINT UNDER SECTION 3301(0) OR 3301(d) OF THE DIVORCE CODE IN DIVORCE 1. The Plaintiff is Dale A. Duppstadt who resides at 4911 Shasta Way, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. The Defendant is Shelley I. Duppstadt who resides at 310 Edwards Street, Harrisburg, Dauphin County, Pennsylvania 17110. 3. The Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 5, 1999 in Mechanicsburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. There were no children born of this marriage. 9. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 10. The Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 10. Plaintiff requests the court to enter a decree of divorce. ~D.~Jd Thomas D. Gould Attorney for Plaintiff 1.0. # 36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 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. Date: 7-1- 0.3 ceD~ A~~~~ ~\\ -- w ..(\ VI ~ 6'\ ~ -J\ ~ -- ...... o ~ ~ ~, () c s: vl> n'lln- ~~:~.., tn '",. -<.' r:::c )'..... ~--. Z:,,-,;' ."...., " :P- (""' -~; ~ a LJ '- ~ () .." --j . ,'-- e , ,-', ,,_.J u -- - '1"\ rr'." -:,l"'-rl ".:..~ :b """ {~, ::J .,;- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA [')0 If. G. bU(fl-Smd1. Plaintiff Vs FileNo. O?l-,=)J/G C:IVII IN DIVORCE ~ r. 11 't151nnJ Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x"] _ prior to the entry of a Final Decree in Divorce, or ---'t- after the entry of a Final Decree in Divorce dated .lYe _ Z I, za.)~, hereby elects to resume the prior surname of biller , and gives this written notice avowing his / her intention pursuant to the provisions of 54 P.S. 70.4. Date: Llp(\ \ \ y,:2wS ~~" UCL-'flfJ\hxtst Signature - ,<)1'11 t~,~ 'i)lli'L, ___ Sign ure of name bemg resumed COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF~I\""'.l'lW I (),,~cI ) .-~ On the ~ day of I'Ipri ( ,200.'i, before me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that lw-/ she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seaL NOTARIALSEAL JOD" S. SMITH, NOTARY PUBlIC Carlisle Boro, Cumberland Gounly My CorrvnIssion EJ<1Jires April 4. 2009 0~J S SrmH1 Prothonotary or Notary Public ~> ~ ~ ~ '>--> 4 ~ ~ ~ ~ '^ ~ ~ --.j c! \ ~-". ~ ~..) <f' -, ;;:;-1 ~) OJ ~ ---\ ~'l'"' ~., ~:~t~:.~. ......j' "'-;? ~ :..., DALE A. DUPPSTADT, PLAINTIFF IN THE COURT OF COMMON P CUMBERLAND COUNTY, PENNSY AS ANIA v. NO. 03 - 3119 SHELLEY I. DUPPSTADT, DEFENDANT IN DIVORCE AFFIDAVIT OF CONSENT 1 _ A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on July 1, 2003. 2. The marriage of Plaintiff and Defendant is irretrie bly broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a Final Decree of Divorce a ter service of notice of intention to request entry of the decree I acknowledge that pursuant to Rule 1920.42(e) I have waived the requirement that I receive notice of intention to request entr of the decree. I verify that the statements made in this Affidavit are rue and correct. I understand that talse statements herein are sub'ect to the penalties of 18 Pa. C.S. Section 4904 relating to uns orn falsification to authorities. DATED: ~~ --, . '"'. -(:""1 .~ ,......, .,;. 1 ovc... DALE A. ., L__I...- ;d: DUPPSTADT DALE A. DUPPSTADT, PLAINTIFF IN THE COURT OF COMMON P CUMBERLAND COUNTY, PENNS ~IA v. NO. 03 - 3119 SHELLEY I. DUPPSTADT, DEFENDANT IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint In Divorce under Section 3301 (c) of the Divorce Code was filed on July J, 2003. 2. The marriage of Plaintiff and Defendant is irretrie bly broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a Final Decree of Divorce ater service of notice of intention to request entry of the decree I acknowledge that pursuant to Rule 1920.42 (e) I have waived the requirement that I receive notice of intention to request entr of t:he decree. I verify that the statements made in this Affidavit arc t ue and correct. I understand that false statements herein are subj ct to the penalties of 18 Pa. C.S. Section 4904 relating to unsw rn falsification to authorities. DATED: 1:1./;1//;)1 I f '...."; '.' ~ ----- - DALE A. DUPPSTADT, PLAINTIFF IN THE COURT OF COMMON P CUMBERIJI.ND COUNTY, PENNSY AS :ANIA v. NO. 03 - 3119 SHELLEY I. DUPPSTAD T, DEFENDANT IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree without not'ce. 2. I understand that I may lose rights concerning alim ny, division of property, lawyer's fees or expenses if I do not c aim them before a divorce is granted. 3. I understand that I will not be divorced until a div rce decree is entered by the court and that a copy of the decree ill be sent to me immediately after it is filed with the prothonot ry. I verify that the statements made in this Affidavit are t ue and correct. I understand that false statements herein are subj ct to the penalties of 18 Pa. C.S. Section 4904 relating to unsw rn falsification to authorities. DATED: 1'/ ,) '1 "' - h -- (\ ,- J lC'-0-.rJ' DALE A. DUPPSTAD~ DALE A_ DUPPSTADT, PLAINTIFF IN THE COURT OF COMMON P CUMBERIJ\ND COUNTY, PENNS S ~IA v. NO. 03 - 3119 SHELLEY I. DUPPSTADT, DEFENDANT IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree without no ice. 2. I understand that I may lose rights concerning ali ony, division of property, lawyer's fees or expenses if I do not laim them before a divorce is granted. 3. I understand that I will not be divorced until a di orce decree is entered by the court and that a copy of the decree ill be sent t~o me irmnediately after it is filed with the prothonot ry. I verify that the statements made in this Affidavct are rue and correct. I understand that false statements herein 'He sub. ect to the penaJties of 18 Pa. c.s Sec~ion 4904 relating to uns OrIl falsification to authorities. DATED: /2jJlf)J1 ,. ,. , (-:.:: c - ~ DALE A. DUPPSTADT, PLAINTIFF IN THE COURT OF COMMON PL CUMBERLAND COUNTY, PENNSYL v. NO. 03- 311't SHELLEY I. DUPPSTADT, DEFENDANT IN DIVORCE ACCEPTANCE OF SERVICE S IA I, Shelley I. Duppstadt, accept service of the Div ree Complaint in the above captioned matter. Dated: C) t 01--- lit. 2(YY~ V Street PA 17110 r",) c. DALE A. DUPPSTADT, PLAINTIFF IN THE COURT OF COMMON P CUMBERLAND COUNTY, PENNSY AS :ANIA v. NO. 03 - 3119 SHELLEY I. DUPPSTADT, DEFENDANT IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following informa ion, to the Court for the entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Se tion 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: On Jul 3. Date of execution of the affidavit of consent by 2003 by Acceptance of Service. Section 3301 (c) of the Divorce Code: By Plaintiff, Decembe 8, 2004; By Defendant, December 14, 2004. 4. Related claims pending: N 5. Date Plaintiff's Waiver of Notice in s 3301(c) div rce was filed with the Prothonotary on December 17, 2004. Date Defendant's Waiver of Notice in s 3301(c) divo ce was filed with the Prothonotary on December 17, 2004. Thomas D. Gould, Esquire Attorney For Plaintiff .. . . . . . . . . . . . . . . . . . .. . . . :f; :+; :t; :f. . 1t;:+; :f. :f. :f. :f'f.;t:+lf.:+ :f. +' ~ ~;t;:+':+':f. +'+: . . IN THE COURT OF COMMON PLEA OFCUMBERLANDCOUNTY STATE OF PENNA. DALE A. DUPPSTADT, . . No. 03-3119 CIVIL . . . . . Plaintiff VERSUS . . . . . SHELLEY I. DUPPSTADT, . . Defendant . . . DECREE IN . . . . . . . . . . . . . . . . . . . . . . . . . . . DIVORCE \}~'t - ~~T is ORDERE AND AND NOW, DALE A. DUPPSTADT , PLAINTIFF, DECREED THAT SHELLEY I. DUPPSTADT , DEFENDAN , AND 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 HA NOT YET BEEN ENTERED; NONE . . . . PROTHONOT RY . . . . ATTEST: . . . . . . . . . . . . . . . / . Of Of Of :t :f.:t:f ... ... ;+: 'f. :f. 'to 'to:f. '+ +.:+ :+. '" Of. Of' . . . . . . . . "":t: :f. "l' . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~~ h qe ~ ~2:!'!/L. 46!.0;0 - q ~ fzv ~ /W-?n1r' ~- p7(} /Ie?' C'('. C'/ SAlOIS HUFF, FLOWER & LINDSAY AlTORNEYS.AT-LAW 26 W. High Street Carlisle, PA I[ ELIZABETH J. PECORA, Plaintiff/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. CHRISTOPHER S. PECORA, Defendant/Respondent NO. 2002 - 3119 CIVIL TERM IN CUSTODY PETITION FOR SPECIAL RELIEF NOW COMES Elizabeth J. Beam, formerly Elizabeth J. Pecora, by and through her counsel, Saidis, Shuff, Flower & Lindsay, and petitions this Honorable Court as follows: 1. The parties hereto are the parents of three children: Samuel C. Pecora, born May 22, 1994; Rachel E. Pecora, born September 16, 1995; and Matthew S. Pecora, born August 20,1999. 2. The parties negotiated a Custody Agreement and Stipulation on July 30, 2005 so that Petitioner could relocate with the children to Missouri. The Custody Agreement and Stipulation was entered as a Court Order on August 11, 2005. A copy of the Stipulation and Order is attached hereto as Exhibit "A". 3. The Custody Agreement and Stipulation was negotiated over an approximate eight hour period prior to Petitioner's relocation. It calls for the children to visit with Respondent over the Christmas holidays, Spring break, and in the summer. 4. Orders prior to this most recent Order have contained a provision that prohibited the Respondent from using physical discipline with the children. However, the parties' Custody Agreement and Stipulation, by an inadvertence, does not include that provision. 5. Petitioner is attempting to obtain tickets for the children to travel for the Christmas holidays at a decent cost. In doing so, and in reviewing the Agreement and SAIDlS iHUFF, FLOWER & LINDSAY Al1'ORNEYS.AT-LAW 26 W. High Street Carlisle. P A II Stipulation, she noted, for the first time, that the prohibition against physical discipline had been left out. 6. Petitioner has attempted to get the agreement of the Respondent to add a provision prohibiting physical discipline by Stipulation. but Respondent refuses to agree. 7. The psychological expert who testified in the parties' case before this Honorable Court, recommended, strongly. that the prohibition against physical discipline continue. 8. Petitioner is unwilling to send the children for Christmas vacation without such a protection in the Court Order. 9. The undersigned has consulted with counsel for Respondent who does not agree to the relief requested. WHEREFORE, Petitioner prays this Honorable Court to hold a meeting in chambers, and after such a meeting. to amend the Custody Agreement and Stipulation of the Parties by returning to it a provision that Respondent shall not physically discipline the children while they are in his custody. SAlOIS, SHUFF, FLOWER & LINDSAY Carol J. Lindsay, squ Supreme Court ID N 26 West High Str. Carlisle, PA 17013 717-243-6222 Exhibit "A" -, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ELIZABETH J. PECORA, Plaintiff No. 02-3119 Civil Tenn Civil Action - Law v. IN CUSTODY CHRISTOPHER S. PECORA, Defendant ORDER OF COURT NOW, this ) tM--day of r;U9 ,2005, upon consideration of the within Custody Agreement and Stipulation, the terms of the Agreement and Stipulation are hereby made an Order of Court. TRUE COpy FROM RECOr.1D In TllSi"l\{l.l1lj' wnafoof, I hllf9 \J1!10SlJ't my h,iMi ~ :'1~~j r;!~r;~' Pa. ~Y~"ot~~rg By the Court, N! V \'fJ 4 J.c1fi- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA o c:. :.:.:. ~,{.'j r'rY"1 -.7 -;~' ~(;) ~;~_., ~~~/; _:::c("', )>-('- :3 "', ELIZABETH J. PECORA, Plaintiff No. 02-3 119 Civil Tem1 Civil Action - Law v. IN CUSTODY CHRISTOPHER S. PECORA, Defendant CUSTODY AGREEMENT AND STIPULATION THIS AGREEMENT, made this 30(1-. day of J (/71 2005, by and ....' c:-,) "c;> <J' "'" (;: G~ I U) between Christopher S. Pecora, of Cumberland County, Pennsylvania, party of the first part, hereinafter referred to as "Father," and Elizabeth J. Beam (formerly Elizabeth J. Pecora), of Cumberland County, Pennsylvania, party of the second part, hereinafter referred to as "Mother," or collectively referred to as "the Parties." WHEREAS, Father and Mother desire to provide for the custody of their three children, Samuel C. Pecora, born May 22,1994; Rachel E. Pecora, born October 16,1995; and Matthew S. Pecora, born August 20, 1999 (hereinafter collectively "the Children"). WHEREAS, the parties desire the provisions of the present Custody Agreement and Stipulation to be approved by this Honorable Court and entered as a court order with the same force and effect as though said order had been entered after Petition, Notice and Hearing. NOW, THEREFORE, the Parties, in consideration of the mutually made and to be kept promises set forth herein and for other good and valuable consideration, intending to be legally bound, do hereby covenant, promise and agree as follows: Page 1 of 7 f:\.l),c,l--old"r\Fir111 Docs\(iendocs201J5\JJI,2-J_"l\rectl\L:l\\'CU5(mly.'l,<(w, -0 -,- -~. o ." 1." n1 r=: -om ~ISb ::;;'-- ?:" :L~ ;p.() ;:5' " _-I -.,. ~ ':'1 1'-' 0' 1. Mother shall have sole legal custody of the Childrcn and primary physical custody of the Children. 2. Except as provided hercin below, and unless otherwise agreed by the Parties, Mother shall have primary physical custody of the Children, subject to Father's periods of custody. 3. The parties agree that Mother may relocate to Missouri with the Children and shall retain primary physical custody of the Children, subject to Father's periods of custody as follows: a. SUMMER 1. During the summer of 2005 and upon execution of this Custody Agreement and Stipulation, Father shall have custody of the Children from August 1 at 5:30 P.M. until August 10 at 5:30 P.M. 11. For the summer of 2006. Father shall have custody of the Children for nine weeks. Commencing with the summer of 2007 and m every year thereafter, Father shall have custody of the Children for sixty days. 111. Mother shall notify Father of the commencement date of his summer custodial period by May 1 of each year. IV. At Mother's option, Father's summer custodial period may be divided into two blocks with no more than one week separating the two blocks. In 2006, the option shall be for a four week period and a five week period. Thereafter, the option shall be that Mother may have a one week period with the Children after Father's first thirty days during the summer. Page 2 of 7 1':\[ ;s~r f,,[J~r\l:i n Ll Onc.,\GerL<\(w.Q(lq'j "Y;k', >,. 'Y;\'e"m~nu: \h\u,ly. 4 ,(Iv" b. HOLIDAYS 1. CHRISTMAS - In odd-numbered years, Father shall have custody of the Children commenc1I1g on December 23 until Decembcr 30. In even- numbered years, Father shall have custody of the Children commencing on December 26 and until two days before the Children are to return to schooL 11. SPRING BREAK - Father shall have custody of the Children for their annual Spring Break from the Sunday evening preceding the break until the Saturday moming after the break. Mother shall advise Father of estimated arrival time and departure time as early as is reasonably possible. Page 3 of 7 d. EXTRACURRICULAR AND OTHER ACTIVITIES - The parties shall have the exclusive ability to schedule activities for the Children during their own custodial periods. e. TELEPHONE CALLS 1. Beginning on the second day after the non-custodial party's custodial period ends, the non-custodial party shall be entitled to call the Children on alternating days at or about 8:00 P.M. Central Time. If the non-custodial party makes his or her call at or about the above-designated time and must resort to leaving a message, the custodial party shall ensure that the Children retum the call prior to their bedtime. 11. Mother shan provide a cellular phone with an unblocked, unrestricted number on her calling plan for the Children's exclusive use to communicate with the parties. The parties shall equally share the cost of the F:\1Jscr Fo I<!cr\!'ifm Doc,\Cclld[}~.,~()O 5\3 J (,?,} ,ugr~cm~\\t.nlsloo y Adf>c additional phone, Father shall reimburse Mother for one-half of the cost of the Children's phone on or beforc the first of each month, Any additional charges for calls that are not to thc parties on thc provided phone shaH be borne by the party who had custody of the children at the time of the call, Mothcr shall be required to provide the phone only while the parties receive their cellular service from the same company, 111. The parties shall ensure to the best of their abilities that the cellular phone provided to the Children is charged, operational, and within access of the Children in a place that is audible for the Children by 8:00 P,M, Central Time, IV, The Children shall be free to call the non-custodial parent on the provided cellular phone at any time the Children may wish to do so. v. The custodial party shall notifY the non-custodial party of the arrival of the Children on the day of custody exchanges. Vl. All calls to Father shall be to his cellular phone, 4. Each party agrees to keep thc other apprised in writing to the Party's then current mailing address of any and all matters relating to the Children's health, education, welfare, and activities (including, but not limited (0 extracurricular activities, sports, music, school progress, reports cards, medical procedures and appointments, ete). Said inforn1ation shall be provided by e-mail on a weekly basis, The parties shall provide each other with updated e-mail addresses for the purposes of this paragraph, The only non-e-mail documentation Mothcr must provide is a school calendar, report cards and any school progress reports, which may be provided electronically if possible, Page 4 of 7 F :\U'Cf I:, >I, Icrl!'; nl L Doc,\Gcndocs ;(J(l5'c 1 JG2- ~_" 1:,,-",;l\\<'''1 ,,'.cdGd~i .4 .<.lee 5. TRAl\SPORTATION - Mother shall provide transportation for all custody exchanges: Mother shall also bear the cost of transp011ation of the Children for all custody exchanges. For thc first two years after the date of execution of this Agreement, the custodia] party or a responsible adult with whom the children are familiar shall accompany the children whenever they are transp01ied by air for custody exchanges. The custodial paJ1y shall pay for the transportation cost of the individual accompanying the Children. Whenever the Children are transported by Mother by automobile, the exchanges shall occur at the WalMart in Carlisle, Cumberland County, Petllisylvania. 6. Neither party shall consume nor be under the influence of alcohol when they are with the Children, nor shall the paJiies knowingly allow any third party to be with the Children while the third party is consuming or is under the influence of alcohol if the Childrcn are not Page -t of 1 under parental supervision. 7. Neither party shall disparage the other parent to the Children, and they shall prevent the Children from being exposed to third parties disparaging the other parent. 8. The Parties shall ensure that none of the Children possess any firearms or other weapons in an unsupervised situation. 9. The Parties shall not knowingly allow the Children to view movies rated PG-13 or higher without parental guidance during the movie, and the Parties shall not allow the Children to play or view video games or music that are rated beyond the child's age. lO. To the extent that the Parties' determination of jurisdiction is enforceable. the Parties agrce that jurisdiction and venue for purposes of custody ofthc Children shall remain C \DOClJl"cnt, and Settjngs\ClI:L)]\Lil"al Se:t,ngs".I'c,rljJorary IIllellle1 hles\Conlelll ]E5\()[CZY["6R\3362-~' "!'.c' "':l1t.C"510(lY.~.doc with the Court of Common Pleas of Cumberland County, Pennsylvania, for as long as Father lives in Pennsylvania, unless later modified by the consent of both parties. 11. The Parties agree that this Custody Agreement and Stipulation shall resolve all of the Parties outstanding custody filings with the Court as of the date of execution. Specifically, Petitions for Special Relief arc withdrawn with prejudice, and all Petitions for Contempt are withdrawn without prejudice. Issues raised in any outstanding Petitions for Contempt may be raised in future Petitions only if the party is able to allege an additional act of contempt of this Agreement after the date of its incorporation into an Order of Court. All prior Orders of Court rcgarding custody in this matter are vacated. 12. Contact information for regular daycarc providers shall be exchanged by the parties. At least one week prior to Father's summer custodial period, he shall provide contact information for any daycare provider to be employed on a regular basis through the summer to Mother. One week prior to any period of time the Children will be on vacation away trom the custodial party's residence, the custodial party shall provide the location and a landline phone numbcr. Also, the Children will always travel with their cellular phone provided undcr Paragraph 3(e). 13. Mother shall provide clothing for the Children for Father's custodial periods. The clothing provided shall be adequate for the season, and shall bc clean and in good repair. Father shall return all of the clothing in like condition. Page 6 of 7 F ;\i ,; '~r F" Id~r\hnn D()cs\Genl!(lcs2I1Wi\J] (,2 - ~ ,a~rccll1cni ,<; 1.1.'\1 ".1 y _,1 .<lll( 14. This Agreement may be modified in writing by the parties' mutual consent at any time without resort to the Court. IN WITNESS WHEREOF, the Parties have set their hands and seals the day and year first above written. F,\UscrFolder\Fiml Dncs\Gclldflcs20(j5"J3r,2-],agrcc"lCrll.cuslody.4.uoc Christoph ~" \':li eth J. ea Page 7 of 7 (SEAL) !SEAL) SAlOIS SHUFF, FLOWER & LINDSAY AITORNEYS-AT-LAW 26 W. High Street Carlisle, PA 11 VERIFICATION I, Carol J. Lindsay, the undersigned, hereby verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsifi (J Carol J. Lindsay! Petitioner , y for SAlOIS HUFF, FLOWER & LINDSAY ATTORNEYS-AT-lAW 26 W. High Street Carlisle, PA II ELIZABETH J. PECORA, Plaintiff v. CHRISTOPHER S. PECORA Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002 - 3119 CIVIL TERM IN CUSTODY CERTIFICATE OF SERVICE AND now, this 26th day of October, 2005, I hereby certify that' served the within Petition for Special Relif this day by depositing same in the United States Mail, First Class, Postage Prepaid, in Carlisle, Pennsylvania, addressed to: Sean M. Shultz, Esquire Knight & Associates 11 Roadway Dr., Suite B Carlisle, PA 17013 SAIDIS, SHUFF, FLOWER & LINDSAY ~. . c. 1~~~~!~~(:,;5' (5-1 1 2 Carol J. Lindsay, Esquire r~ ---: . 10\ .-J C "'-' '-'\ R ~v J (" .--. 'JV \...J\ .-s. d d-