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aintiff
V.
"a/&,tbefendant
JUL 2 7 1999
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. W-- 4i CIVIL TERM
CUSTODY
AND NOW, this day of , 1997, the terms of
the attached Custody Stipulation and Agreement are hereby made an
Order of Court.
By the Court,
, J.
Send to:
Plaintiff, = see
I,,NNamrre
Address
Address
Defendant
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Address
Address
9
?' ^" U?hP?, Plaintiff
v.
on1 e1 Defendant
Made by and between ,
hereinafter "Mother," and
hereinafter "Father."
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
4q- 9Ja(e
NO. *7- CIVIL TERM
CUSTODY
WHEREAS the parents have a child/children, namely:
DATE. OF BIRTH
hereinafter "child1ch+Id&'0W'; and
WHr'ms, the parents wish to enter into an agreement
relative to custody, partial custody and visitation of the
child/zbii,drwT, and
NOW THEREFORE the parents agree as follows:
1. Mother and Father shall have shared legal custody of the
child/ehtk?dren, meaning that they shall share the legal right to
make major decisions affecting the best interest of the
child/cam and all of the major matters related to the
child/ohil,dren, including, but not limited to, medical, religious
and educational decisions.
2. Mother/Father shall have shared physical custody of the
child/ meaning that the Mother and Father shall have
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approximately equal physical possession and control of the
child/old ldW.
1. The parties will share custody according to the
following schedule: (Select (a) or (b))
a. AS AGREED Qas agreed to by the
parents. (If you think, that you do not need a set schedule,
you may stop here and sign the agreement at the end.)
b. ACCORDING TO THE FOLLOWING SCHEDULE -
The father's periods of custody including weekends and
weekdays are:
c. The mother's periods of custody including weekends
and weekdays are:
d. HOLIDAYS OTHER THAN THANKSGIVING AND CHRISTMAS (Initial
choice 1 or 2 or leave blank)
1.
Holidays shall be
defined as: (Initial holidays that you agree to
alternate.)
New Years Day
Easter Sunday
Memorial Day
Independence Day (Fourth of July)
Labor Day
During even numbered years, Mother/Father shall have the
child/children on New Years Day, Memorial Day and Labor Day and
the other parent shall have the child/children on Easter Sunday
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and Irn}ependence Day from .m. through .m.
(Time) (Time)
During odd numbered years, the other parent shall have the
child/children on New Years Day, Memorial Day and Labor Day at
the above times and Mother/Father shall have the child/children
on Easter Sunday and Independence Day at the same times.
2. SPLIT Holidays shall be defined as:
(initial holidays that you agree to split and not
alternate.)
New Years Day
Easter Sunday
Memorial Day
Independence Day (Fourth of July)
Labor Day
Holidays shall be split between the parents with the parent
that does not have primary physical custody having the
child/children beginning at .m. on the day of the
(Time)
holiday through m. on the same day.
(Time)
e. MOTHERS DAY AND FATHERS DAY
(Initial if agreed)
Regardless of any weekend schedule agreed to in this agreement,
Mother shall always have the child/children on Mother's Day from
m. through .m. and Father shall always
(Time) (Time)
have the child/children on Father's Day at the same times.
f. THANKSGIVING Thanksgiving holiday
(Initial if agreed)
shall be defined as beginning on at .m.
(Day of week) (Time)
19
through at .m.
(Day of week) (Time)
(Initial choice 1 or 2 or leave blank)
1. ALTERNATING The parents hall
alternate Thanksgiving holiday with Mother/Father
having the child/children on even numbered years and
the other parent having the child/children on odd
numbered years.
2. SPLIT The parents shall split the
Thanksgiving holiday with MGm n/FATHER having the
child/children from the beginning of the Thanksgiving
holiday through Day of Week at
.m. and the other parent having the child/children
(Time) from that time through the end of the
Thanksgiving holiday.
g. CHRISTMAS Christmas holiday
(Initial if agreed)
shall be defined as beginning on December at M.
(Date) (Time)
ending on at _.m. each year.
(Date) (Time)
(Initial choice 1,2, or 3 or leave blank)
1. Split Mother/Father shall have the
child/children from the beginning of the Christmas holiday
through December at _.m. and the other parent
(Date) (Time)
shall have the child/children from that time to the end of the
Christmas holiday in even/odd numbered years. In the other
years, the other parent shall have the child/children from the
beginning of the Christmas holiday through the above time, and
20
custody shall then be transferred at the above time to
Mother/Father.
2. ALTERNATING Mother/Father shall have
the child/children during the Christmas holiday in even/odd
years. In the other years, the other parent shall have the
child/children during the Christmas holiday at the same times.
3. FIXED Mother/Father shall each year
have the child/children from the beginning of the Christmas
holiday through December at .m., and the
(Date) (Time)
other parent shall each year have the child/children from that
time to the and of the Christmas holiday.
h. SUZCM VACATION (Fill this in if the summer schedule
will differ from the school year schedule on a regular basis or
if you wish to have the right to take the child (ran) on a
vacation trip.)
The mother shall
(Initial if agreed)
shall have the child/children for weeks during the summer
(Number)
vacation. Father shall have the child/children for weeks
during the summer vacation. The summer vacation is as follows:
i. MISCELLANEOUS The parents also agree
(Initial if agreed)
to the following:
J. Additional periods of physical custody shall be provided
21
as agreed to by the parties.
4. Transportation of the child/children shall be provided
as follows:
(Fill in the blank)
5. Neither parent shall do anything which may estrange the
child' from the other parent or injure the opinion of the child as
to the other parent, or which may hamper the free and natural
development of the child's love and affection for the other
parent.
6. Neither parent shall consume alcoholic beverages to the
point of intoxication or consume any unprescribed controlled
substances (drugs) while the child/children is in their care.
7. Each parent agrees to provide the other parent with an
address and telephone number through which the parent may be
contacted during periods of custody of the child/children. Each
parent further agrees to inform the other parent of any medical
emergencies that arise while the child/children are in that
parent's care.
8. The failure of either parent to insist on strict
compliance with this agreement shall not prevent the parent from
insisting on strict compliance in the future.
9. The parents agree and desire that this agreement be made
an Order of Court of the Court of Common Pleas of Cumberland
County, Pennsylvania.
IN WITNESS WHEREOF, the parties hereto intending to be
22
4
legally bound by the terms hereof, request this Court to enter an
order to reflect the above terms.
Date:
Date:
A ?
ig99 .
-""'?NoTARIAL SEAL
NEFF, NDTARY PUBL
SONORA T. COUNTY
CARLISLE BORO. CUMOERLAND COMMISSION O' RES NOVEMBER 15. 10
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TRACEA L. LAUCKNER IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
DANIEL SEIBERT NO. 99-4526 CIVIL TERM
ORDER OF COURT
AND NOW, this 29th day of July, 1999, it
appearing to the Court that the natural father, Jeremiah
Shoemaker, is not a party to these proceedings, it is
hereby ordered and directed that he be joined pursuant to
Pennsylvania Rule of Civil Procedure 1915.6. This hearing
will be rescheduled at the request of any party after
proper joinder has been effectuated.
By the Cour
Edward E. Guido, J.
Tracea Lauckner
848 Baltimore Pike
Gardners, PA 17324
Daniel Seibert Y'
848 Baltimore Pike
Gardners, PA 17324
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TRACEA L. LAUCKNER IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
DANIEL SEIBERT NO. 99-4526 CIVIL TERM
ORDER OF COURT
AND NOW, this 29th day of July, 1999, the
Plaintiff's Petition for Leave to Proceed as an Indigent is
GRANTED.
By the Co
Edward E. Guido, J.
Tracea Lauckner
848 Baltimore Pike
Gardners, PA 17324
Daniel Seibert
848 Baltimore Pike
Gardners, PA 17324
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Daniel Seibert
84Q Baltimore Pike
Gardners, Pa. 17324
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Tracea Lauckner
848 Baltimore Pike
Gardners, Pa. 17324
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TRACEA L. LAUCKNER IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
V.
DANIEL SEIBERT : NO. 99-4526 CIVIL TERM
ORDER OF COURT
AND NOW, this a day of JULY, 1999, a hearing on the above
matter is scheduled for Thursday, July 29, 1999, at 9:00 a.m. in Courtroom # 5. At
said hearing, we will take testimony regarding the stipulation of the parties and
decide whether to enter an order as requested. We will also address Plaintiffs
Petition for Leave to Proceed as an Indigent.
By the
Edward E. Guido. J.
Tracea Lauckner
848 Baltimore Pike
Gardners, Pa. 17324
Daniel Seibert
848 Baltimore Pike fll /JfS ?wii+t' F,?
Gardners, Pa. 17324 / 6y ?hQ?/i` 7n2,f 9q
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Q.Qdw-L , Plaintiff
v.
&'+_ , Defendant
JUL 2 7 199 9?
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
q9. 46.2(e
NO. 9a- CIVIL TERM
CUSTODY
1 /ZQ?OQ aV4 "Plaintiff in the above-titled
action, on this I day of 19971
respectfully requests this Honorable Court to grant her leave to
proceed as an indigent to the extent that she be relieved from
paying the fees and costs in this procedure.
2. Plaintiff has been screened for income eligibility at
Legal Services, Inc., has been determined eligible, and has
attended a custody class at Legal. Services taught by a private
attorney who was providing services free of charge as part of the
Cumberland County Bar Association's nro bono plan. Verification
is attached.
3. Plaintiff has attached an affidavit in support of this
petition.
By the
I verify that the Plai?tiff has been determined by Legal
Services, Inc. to meet their financial eligibility guidelines and
that.the Plaintiff has attended a custody class.
27
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1 ?Q z Qoe%v a IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COMM, PENNSYLVANIA
V. 49- 45ico
C ?o r? NO. Pa CIVIL TERM
fJ1?V /o ? L • `??? ; Defendant CUSTODY
AFFIDAVIT IN SUPPORT OF PETITION
FOR LAVE TO PROCEED IN FORM PAOPERIS
1. I am the plaintiff in the above matter and because of my
financial condition am unable to pay the fees and costs of
prosecuting, defending, or appealing the action or proceeding.
2. I am unable to obtain funds from anyone, including my
family and associates, to pay the costs of litigation.
3. I represent that the information below relating to my
ability to pay the fees and costs is true and borrect.
(a) Name:
Address
Social Security Number: =?Q ?) - Al (q?)x `1
(b) If you are presently employed, state
Employer:
Address:
Salary or wages per month:
Type of work:
If you are presently unemployed, state
Date of last employment: /
Salary or wages per month:
Type of work: h Q1 r
28
(c) other income within the past twelve months
Business or profession:
Other self-employment:
Interest:
Dividends:
Pension and annuities:
social Security benefits:
Support payments: 4o -ol
/
Disability,payments: l
Unemployment compensation and
supplemental benefits: X/
Workman's compensation:
Public Assistance: 00,
-
other:/
(d) Other c n ibutions to hpsehold support
(Wife) (???Name
If your (husband), (Vi/o} is pnployed, state
Employer: -L?/4 V L," X-1% -i LI/ I j II/
Salary or wages per oath,
Type of work: oy?
Contributions from children:
(a) Property owned
Cash:
Checking Account: Sv
Savings Account:
Certificates of Deposit:
Real Estate (including home):
29
Motor vehicle
Make ? Year
Cost Amount owed
Stocks; bonds:
Other: ??
(f) Debts and obligations
Mortgage:
Rent: ??
Loans:
Monthly
(g) Persons dependent upon you for support
(wife) (Husband) Name:
Children, if any: l
Name: ds/'? t Age:
4. I understand that I have a continuing obligation to
inform the court of improvement in my financial circumstances
which would permit me to pay the costs incurred herein.
5. 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
falsification to
Date:l
30
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fa-intiff
v.
)„ 2/ ) &, befendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97- CIVIL TERM
CUSTODY
AND NOW, this day of , 1997, the terms of
JUL 2 7 1999
v
the attached Custody Stipulation and Agreement are hereby made an
Order of Court.
Send to:
Plaintiff, 2r0 ,4g
By the Court,
, J.
/ Name
lea ?}i.nm^P P. /Z?d
Address
Address
Defendant L/ C / C
ame
)Eel-
P,Lie i2-o/ri lnm5 P, /'C'11
Address
Address
9
plaintiff
V.
Sz,&,tbefendant
JUL 2 7 199a ?
IN THE COURT OF COMHON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97- CIVIL TERM
CUSTODY
AND NOW, this day of , 1997, the terms of
the attached Custody Stipulation and Agreement are hereby made an
Order of Court.
By the Court,
, J.
Send to:
Plaintiff, nro Ag
/ Name
4 ?Nc% ;,nom p. mod
Address
Address
Defendant
ame
Address
6av(Lv1--'s Pa !?3a u
Address
9
Plaintiff
v.
?? Defendant
Dni el e. cJek?eA
JUL 2 7 1999
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97- CIVIL TERM
CUSTODY
ORDER
AND NOW, this day of , 1997 , upon
consideration of the plaintiff fIs Petition and Affidavit in
support of Petition for Leave to Proceed In Forma PttM eris, it is
hereby ORDERED and DECREED that Plaintiff,
may file the attached custody action in form pane is and proceed
to the termination of the proceedings without payment of filing
fees or costs.
J.
26
/' 0- L.
l? Plaintiff
V.
?.ni e? ?• JUL 2 7 1999
5G)IPJ ?- ,?, Defendant
N,
IN THE COURT OF COMMON PLEAS OF
CDNBERLAND COUNTY, PENNSYLVANIA
NO. 97- CIVIL TERM
CUSTODY
ORDER
AND NOW, this day of _ , 1997 , upon
consideration of the plaintiff's petition and Affidavit in
support of Petition for Leave to Proceed In Forma pave is, it is
hereby ORDERED and DECREED that Plaintiff, I
may file the attached custody action j,II form ggun eris and proceed
to the termination of the proceedings without payment of filing
fees or costs.
J.
26
Plaintiff
V.
Defendant
?ni 2? ?• `JC?
JUL 2 ? 099 J
u
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97- CIVIL TERM
CUSTODY
ORDER
AND Now, this day of , 1997 , upon
consideration of the plaintiff's Petition and Affidavit in
support of Petition for Leave to Proceed in Forma Pauneris, it is
hereby ORDERED and DECREED that Plaintiff,
may file the attached custody action in f= BAuneris and proceed
to the termination of the proceedings without payment of filing
fees or costs.
J.
26