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DANIEL L. HENSLEY and : IN THE COURT OF COMMON PLEAS OF
ELVA ARLENE GLASS HENSLEY, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
VS.
KATHY H. TRAYER,
Defendant
CIVIL ACTION -LAW
NO, X19 S? CIVIL TERM
IN CUSTODY
/ORDER QF COURT
AND NOW, this (4 day of SF. , 1999, upon presentation
and consideration of the within Custody Stipulation and Agreement said Stipulation and
Agreement is hereby made an Order of Court. All prior Orders in this matter are hereby
vacated.
BY THE COURT,
d
FILED-OFFICE
OF T,,,'= r"-1r )N,10TA9Y
99 SEP 21 Ali I I1 53
CUI'AHR'LiANG G MY
PENNSYLVANIA
DANIEL L. HENSLEY and : IN THE COURT OF COMMON PLEAS OF
ELVA ARLENE GLASS HENSLEY, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
VS. CIVIL ACTION - LAW
KATHY H. TRAYER, NO.9q'S" CIVIL TERM
Defendant IN CUSTODY
CUSTODY
STIJ!ULATION AND AGREEMENT
THIS STIPULATION AND AGREEMENT entered into the day and year
hereinafter written, by and between DANIEL L. HENSLEY and ELVA ARLENE
GLASS HENSLEY, (hereinafter referred to as "Grandparents") and KATHY H.
TRAYER, (hereinafter referred to as "Mother").
WHEREAS, the Grandparents are the natural Grandparents and Mother is the
natural parent of the child, namely, Carrie Elizabeth McGee, born August 1, 1982,
(hereinafter referred as the "child"); and
WHEREAS, the child is a product of rape by the biological Father, (hereinafter
referred to as "rapist") and;
WHEREAS, the rapist was never known to Mother, never identified, and never
prosecuted; and
WHEREAS, the rapist is still unknown and has never bad any contact with the
child or paid support for the child; and
WHEREAS, the parties wish to enter into an Agreement regarding the physical
and legal custody of the child based upon the parties' present circumstances.
NOW, THEREFORE, in consideration of the mutual covenants, promises and
agreements as hereinafter set forth, the parties stipulate and agree as follows:
1. The parties shall have shared legal custody of the child.
2. Grandparents shall have primary physical custody of the child.
3. Mother shall independently have periods of partial physical ustody with the
child as the parties may agree.
4. The parties will keep each other advised immediately relative to any
emergencies concerning the child and shall, further, take any necessary steps to ensure
that the health and well being of the child are protected. During such illness or medical
emergency, each party shall have the right to visit the child as often as he/she deems
consistent with the proper medical care of the child.
5. None of the parties shall do anything which may estrange the child from the
other parties, or injure the opinion of the child as to the other parties, or may hamper the
free and natural development of the child's love or affection for the other pasties.
6. Any permanent modification or waiver of the provision of this agreement must
be in writing and shall be effective only if made in writing and executed with the same
formality as this Stipulation and Agreement. This provision is not intended to prohibit
the parties from temporarily agreeing upon modifications from time to time to provide
for the best interests of the child.
7. The child has resided in Cumberland County, Pennsylvania with her Mother
for the past ten (10) years, therefore, the Court of Common Pleas of Cumberland County
has jurisdiction over the issue of custody of the child, The parties wish to have the
within Stipulation and Agreement entered as an Order of Court in the Court of Common
Pleas of Cumberland County which has jurisdiction of this matter and which Court shall
retain jurisdiction of this matter should circumstances change and either parties desire or
require modification of the Order.
g. The parties acknowledge that entering into this Stipulation and Agreement,
there has been no fraud, concealment, overreaching, coercion, or other unfair dealing on
the part of either party.
9. The parties acknowledge that they have read and understand the provisions of
this Stipulation and Agreement. Each party acknowledges that the Stipulation and
Agreement is fair and equitable and that it is not the result of duress or undue influence.
IN WITNESS WHEREOF, the parties hereto intending to be legally bound by the
terms hereof, set forth their hands and seals the day and year herein mentioned.
WITNESS:
Date DANIEL L. HENSLEY
Date ELVA ARLENE GLASS HENSLE
Date THY H 'RAYER 61
COMMONWEALTH OF 1ENNS: ?..S*6VANi c
hu u Ste, SS.
COUNTY OF 81 i;kl: ?
On this the a 3'J day of 411999, before me, the undersigned
officer, personally appeared DANIEL L. HENSLEY, 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 hereunto set my hand and official seal.
i'i C 61ditS?lOfl -EXPIRE
S`?yp ?p
COMMONWEALTH OF PENNSYYLVKNIA :
XX6*610- : SS.
COUNTY OF Ek M8ffttAND
On this the 3 rd day of Z -ak 'd E- , 1999, before me, the undersigned
officer, personally appeared ELVA ARLENE GLASS HENSLEY, 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 hereunto set my hand and official seal.
o:1t,n, iJ.d EXPEIL'?,?L3q zo-"
STATE OF PENNSYLVANIA
COUNTY OF CUMBERLAND SS.
On this the P? day of
officer, personally appeared 4&- , 1999, before me, the undersigned
KATHY H. TRAYgR
Proven) to be the ' known to me (or satisfactorily
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 hereunto set my hand and official seal.
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