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HomeMy WebLinkAbout99-06723F Li ?' 1 I . ^ ?1 ?J i U ti ,? DAVID A. SHETROM, Petitioner VS. KIMBERLY L. GOODLING, Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. - 1999 -G zz? &?/ CIVIL ACTION - LAW CUSTODY/VISITATION AND NOW, this ./J4\ day of, , 1999, upon presentation of the Petition For Custody in connection with the above-captioned matter, it is hereby ORDERED AND DECREED that the executed stipulated Custody Agreement, dated November 2, 1999, become an Order of Court. J. _?: 44 DAVID A. SHETROM, Petitioner Vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. & -1999 - (-7.2 t 6, 17? KIMBERLY L. GOODLING, CIVIL ACTION - LAW Respondent ) CUSTODYNISITATION P ETITI ON-EDR_C1J$TO DY AND NOW, this 51 day of November, 1999, comes the Petitioner, David A. Shetrom, by and through his attorneys, the Law Offices of BATURIN & BATURIN, and files this Petition For Custody: 1. The Petitioner, David A. Shetrom, natural father, an adult individual, sui juris, currently resides at 311 Beaver Avenue, Enola, Cumberland County, Pennsylvania, 17025. 2. The Respondent, Kimberly L. Goodling, natural mother, an adult individual, sui juris, currently resides at 7073 Carlisle Pike, Lot 211, Carlisle, Cumberland County, Pennsylvania 17013. 3. The Petitioner and Respondent are the natural parents of KELSEE NICOLE SHETROM, four (4) years of age, born July 27, 1995, and CODY ALLEN ROBERT SHETROM, two (2) years of age, born June 18, 1997, both of whom currently reside at 311 Beaver Avenue, Enola, Cumberland County, Pa., with natural father. 4. The parties hereto, intending to be legally bound hereby, covenant and agree as follows: a) The parties shall have shared legal custody of their minor children, CODY ALLEN ROBERT SHETROM and KELSEE NICOLE SHETROM. The parties agree that Father shall have primary physical custody of the children and Mother shall have periods of partial physical custody of said children as set forth below: b) Every other weekend from 6 p.m. Friday evening to 6 p.m. Sunday evening. Said visitation will commence upon the signing of this Stipulation. c) Visitation during all holidays will be determined by and between the parties in accordance with both their work and personal schedules. Visitation during all birthdays shall be determined by and between the parties in accordance with both their work and personal schedules. d) Mother shall have two (2) weeks of visitation in the summer. The afore- mentioned 2-week period shall also be determined by and between the parties in accordance with their both their work and personal schedules. e) Both Mother and Father shall refrain from making any derogatory remarks about the other parent in the presence of the children and, to the extent possible, shall prevent third parties from making such comments in the presence of the children. f) Both Mother and Father agree not to impair the other parent's legal or physical custody of the children. Both Mother and Father agree not to attempt to alienate the affections of the child from the other parent. Day to Day decisions shall be the responsibility of the parent having physical custody of the children. f) Any requests for unscheduled visitation by either party must be made at least one (1) week in advance of the date for which visitation was requested. (g) Both Mother and Father make every effort to comply with this agreement and act in no way to hinder or disturb this agreement. 5. This Stipulation is entered into pursuant to the mutual understanding and agreement of the parties hereto and it is the intent of both to become and remain legally 1) bound by the mutual promises and covenants herein contained. 6. A stipulated Custody Agreement to the above Petition For Custody is signed by the parties hereto and is attached to this Petition. WHEREFORE, the Petitioner, David A. Shetrom, respectfully request that this Honorable Court enter the stipulated Custody Agreement as an order for Custody. Respectfully submitted, Dated: November 3, 1999 BATURIN & BATURIN By: Harry M. Baturin Attorney ID #83006 717 North Second Street Harrisburg, PA 17102 (717) 234-2427 Attorney for Petitioner 3 VERIFICATION WE VERIFY THAT THE STATEMENTS MADE IN THIS PETITION ARE TRUE AND CORRECT TO THE BEST OF OUR KNOWLEDGE, BELIEF, AND INFORMATION. WE UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 PA.C.S. 54904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. Date: C\0-ly • 9 `ci 1 1 ( SEAL ) David A. Shetrom 4 DAVID A. SHETROM, ) Plaintiff VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. S-1999 KIMBERLY L. GOODLING, CIVIL ACTION - LAW Defendant ) CUSTODYNISITATION STIPULATION FOR CUSTODY AND NOW, this ? day of November, 1999, the Plaintiff, DAVID A. SHETROM, and Defendant, KIMBERLY L. GOODLING, agree to the following Stipulation For Custody: 1. The Plaintiff, DAVID A. SHETROM, natural father, an adult individual, sui juris, currently resides at 311 Beaver Avenue, Enola, Cumberland County, Pennsylvania, 17025. 2. The Defendant, KIMBERLY L. GOODLING, natural mother, an adult individual, sui juris, currently resides at 7073 Carlisle Pike, Lot 211, Carlisle, Cumberland County Pennsylvania 17013. 3. The Plaintiff and Defendant are the natural parents of KELSEE NICOLE SHETROM, four (4) years of age, born July 27, 1995, who currently resides at 311 Beaver Avenue, Enola, Cumberland County, Pa., with natural father. 4. The Plaintiff and Defendant are the natural parents of CODY ALLEN ROBERT SHETROM, two (2) years of age, born June 18, 1997, who currently resides at 311 Beaver Avenue, Enola, Cumberland County, Pa., with natural father. 5. The parties hereto, intending to be legally bound hereby, covenant and agree as follows: a) The parties shall have shared legal custody of the their minor children, CODY ALLEN ROBERT SHETROM and KELSEE NICOLE SHETROM. The parties agree that Father shall have primary physical custody of the children and Mother shall have periods of partial physical custody of said children as set forth below: b) Every other weekend from 6 p.m. Friday evening to 6 p.m. Sunday evening. Said visitation will commence upon the signing of this Stipulation. c) Visitation during all holidays will be determined by and between the parties in accordance with both their work and personal schedules. Visitation during all birthdays shall be determined by and between the parties in accordance with both their work and personal schedules. d) Mother shall have two (2) weeks of visitation in the summer. The afore- mentioned 2-week period shall also be determined by and between the parties in accordance with their both their work and personal schedules. e) Both Mother and Father shall refrain from making any derogatory remarks about the other parent in the presence of the children and, to the extent possible, shall prevent third parties from making such comments in the presence of the children. f) Both Mother and Father agree not to impair the other parent's legal or physical custody of the children. Both Mother and Father agree not to attempt to alienate the affections of the child from the other parent. Day to Day decisions shall be the responsibility of the parent having physical custody of the children. f) Any requests for unscheduled visitation by either party must be made at least one (1) week in advance of the date for which visitation was requested. 2 (g) Both Mother and Father make every effort to comply with this agreement and act in no way to hinder or disturb this agreement. 6. This Stipulation is entered into pursuant to the mutual understanding and agreement of the parties hereto. NOW THEREFORE, the parties hereto set their hands and seal the date first above written. IN THE PRESENCE OF: (SEAL) DAVID A. SHE?ROM, Natural Father (SEAL) KIMBERLY L. GPODLING, Natural M her