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CRYSTAL A. CHRISTY,
Plaintiff
VS.
RUSSELL H. CHRISTY, JR.,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
:NO.' ^(nl l CIVIL TERM
: IN CUSTODY
AND NOW, this day of pc,*y%,r , 1999, upon presentation
and consideration of the within Custody Stipulation and Agreement said Stipulation, and
Agreement is hereby AFFIRMED as an Order of Court. All prior Orders in this matter
are hereby vacated.
BY THE COURT,
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CRYSTAL A. CHRISTY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION -LAW
RUSSELL H. CHRISTY, JR., : NO. qq- (D114 CML TERM
Defendant : IN CUSTODY
CUSTODY
STIPULATION AND A . F.. NT
THIS STIPULATION AND AGREEMENT entered into the day and year
hereinafter written, by and between CRYSTAL A. CHRISTY, (hereinafter referred to as
"Mother') and RUSSELL H. CHRISTY, JR., (hereinafter referred to as "Father').
WHEREAS, the parties are the natural parents of two (2) children, namely,
Alauria Christy, bom October 29, 1992, and Janay Christy, born January 10, 1996,
(hereinafter referred as the "children"); and
WHEREAS, the parties are divorced and living separate and apart; and
WHEREAS, the parties wish to enter into a comprehensive custody stipulation
and agreement setting forth the physical and legal custody arrangements for the child;
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 or joint legal custody of the children.
2. Mother shall have primary physical custody of the children.
3. Father shall have periods of temporary or partial physical custody of the
children on the following schedule:
a. Every other weekend from Friday evening at 4:30 p.m. until Sunday
afternoon at 2:00 p.m.;
b. Every Wednesday evening from 4:30 p.m. until 8:00 p.m.;
c. At such times when the children have more than two (2) consecutive
days of vacation from school, Father may have one (1) extra day of partial
physical custody at times to be agreed upon by the parties;
d. At other times as the parties may mutually agree with no less than
forty-eight (48) hours notice being given.
4. The children shall always be with Mother during Mother's Day and with
Father during Father's Day from 9:00 a.m. until 7:00 p.m. on that day.
5. The children shall always be with Mother on Mother's birthday and with
Father on Father's birthday from 9:00 a.m. until 7:00 p.m. on that day.
6. The parties shall alternate physical custody of the children on an annual basis
for the following holidays: New Years' Day, Easter, Memorial Day, Fourth of July,
Labor Day, Thanksgiving, and New Years' Eve. The parent who has custody on any
respective alternating holidays shall have the children for the period of 9:00 a.m. until
7:00 p.m. on the holiday. In the event that Father's holiday should occur in conjunction
with his weekend period of physical custody, he shall simply retain physical custody of
the children Sunday night through the Monday holiday. The alternating holiday shall
begin with Mother having physical custody of the children on Labor Day, 1999.
7. During the Christmas holiday season, Father shall have partial physical
custody of the children on Christmas Eve from 12:00 p.m. until 9:30 p.m. and Mother
shall have physical custody of the children from 9:30 p.m. on Christmas Eve until 9:00
a.m. on December 26d.
S. During the summer vacation months, Father shall be entitled to partial physical
custody of the children for a maximum of two to three days per week as the parties may
mutually agree with Father providing Mother with forty-eight (48) hours notice of his
desire to exercise this time.
9. Father shall be responsible for transportation for his periods of partial physical
custody.
10. The parties are the only persons who may drop off or pick up the children
from the babysitter.
11. Neither parry shall take the children out-of-state for more than a daytime trip
without the prior written consent of the other party, which shall state the departure and
return times.
12. Father shall pay child support for the support of both children in the amount
of SIXTY DOLLARS ($60.00) per week. This amount may be paid weekly at a rate of
SIXTY DOLLARS ($60.00); bi-weekly at a rate of ONE-HUNDRED AND TWENTY
DOLLARS ($120.00); or monthly at a rate of TWO HUNDRED AND SIXTY
DOLLARS ($260.00). Under any payment option set forth above the payments shall be
made by Father in a timely fashion.
13. Father shall retain both children on his health insurance. Each party shall be
responsible for one-half (1/2) of all deductible costs and uninsured medical expenses.
W. The parties will keep each other advised immediately relative to any
emergencies concerning the children and shall, further, take any necessary steps to ensure
that the health and well being of the children are protected. During such illness or
medical emergency, each party shall have the right to visit the children as often as he/she
deems consistent with the proper medical care of the children.
15. Neither parent shall do anything which may estrange the children from the
other parties, or injure the opinion of the children as to the other parties, or may hamper
the free and natural development of the children's love or affection for the other parties.
16. 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.
17. The parties desire that this Stipulation and Agreement be made an Order of
Court of the Court of Common Pleas of Cumberland County, and further acknowledge
that the Court of Common Pleas of Cumberland County does, in fact, have jurisdiction
over the issue of custody of the parties' minor children who have resided in Cumberland
County their entire lives and shall retain such jurisdiction should circumstances change
and either party desire or require modification of said Order.
18. 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.
19. 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 AL A. CHRISTY
I
Date USSELL HRIS' , JR.
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i COMMONWEALTH OF PENNSYLVANIA :
. SS.
COUNTY OF CUMBERLAND
On this the ,;9 6 day of '6l f"-l , 1999, before me, the undersigned
officer, personally appeared CRYSTAL A. CHRISTY, 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.
Notarial Seel
Robin J. Gahm, Notuy NbW
Carlisle noro, GUnbedvW Cow*
My Conunisslon Egfts Apr. 17, 2003
STATE OF PENNSYLVANIA
SS.
COUNTY OF CUMBERLAND
On this the IS day of 1999, before me, the undersigned
officer, personally appeared RUSSELL H. CHRISTY, JR., 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 se't my hand and official seal.
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