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Home My WebLink About07-2914IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES E. VERDIER and PAMELA J. VERDIER, his wife, Plaintiffs vs. JASON FARNER and ANGELINA J. DARR, Defendants No. Q ~ ~~ ~ f IN CUSTODY CIVIL ACTION -LAW NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appeazance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. 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. Cumberland County Baz Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717} 249-3166 NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notification. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una Orden contra usted sin previo aviso o notification y por cualguier queja o alivio que es pedido en la petition de demanda. Usted puede perder dinero o sus propiendades o otros derechos importantes para usted. LLEVE ESTA DEMANDAA UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SOFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONAL O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 KNIGHT & ASSOCIATES, P.C. ~~"`f ~~ Sean M. Shultz, Esquire Attorney ID No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17013 (717) 249-5373 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND, PENNSYLVANIA JAMES E. VERDIER and No. D''j - ~~~•~! PAMELA J. VERDIER, his wife, l Plaintiffs IN CUSTODY vs. JASON FARNER and CIVIL ACTION -LAW ANGELINA J. DARR, Defendants COMPLAINT FOR PRIMARY CUSTODY AND NOW, this ~~ day of /' ~~ , 2007, come Plaintiffs, James E. Verdier and Pamela J. Verdier, his wife, by and through their attorneys, Knight & Associates, P.C., and file the following Complaint for Primary Custody in support thereof avers as follows: 1. Plaintiffs are James E. Verdier and Pamela J. Verdier, husband and wife, who reside at 1567 Fairview Avenue, Chambersburg, Pennsylvania 17201. 2. Defendant 3ason Farner resides at 2360 Highway 87 East, Billings, Montana 59101, and Defendant Angelina J. Darr resides at 25 Betty Nelson Court, Lot 125, Carlisle, Pennsylvania 17013. 3. The Plaintiffs seek primary custody of the following child: Name Tyler J. Querry Present Residence Age D/OB l 567 Fairview Avenue Chambersburg, Pennsylvania 17201 13 April 29, 1994 Tyler was born out of wedlock. Tyler is presently in the physical custody of the Plaintiffs. During the past five years, Tyler has resided with the following persons and at the following addresses: a. From Apri12002 to April 2005 with Defendant Angelina J. Darr, her husband, Matthew Darr, Angelina's daughters, Brittany Shea and Sydney Marie Darr, and Angelina's son, Gabriel Darr, at 18 Big Spring Terrace, Newville, Pennsylvania; b. From April 2005 to April 7, 2006 with Defendant Angelina J. Darr, her husband, Matthew Darr, Angelina's daughters, Brittany Shea and Sydney Marie Darr, and Angelina's son, Gabriel Darr, at 83 West Main Street, Newville, Pennsylvania; and c. From April ?, 2006 to present with the Plaintiffs, James Verdier's son, Eric Bailey, Plaintiffs' daughter, Tia Verdier and Tyler's sister, Sydney Marie Darr at 1567 Fairview Avenue, Chambersburg, Pennsylvania. The mother of Tyler is Defendant, Angelina J. Darr and she currently resides at 25 Betty Nelson Court, Lot 125, Carlisle, Pennsylvania. She is married to Matthew Darr. The father of Tyler is Defendant, Jason Farner and he currently resides at 2360 Highway 87 East, Billings, Montana 59101. He is married to Nicole Farner. The maternal great uncle and aunt of Tyler are the Plaintiffs James E. Verdier and Pamela J. Verdier, currently residing at 1567 Fairview Avenue, Chambersburg, Pennsylvania 17201. They are married to each other. 4. The relationship of Plaintiffs to Tyler is that of maternal great uncle and aunt. The Plaintiffs currently reside with Tyler and James Verdier's son, Eric Bailey, Plaintiffs' daughter, Tia Verdier and Tyler's sister, Sydney Marie Darr . The relationship of Defendant, Jason Farner to Tyler is that of natural father. He currently resides with his wife, Nicole Farner and his daughter, Bridgette Baum. 6. The relationship of Defendant, Angelina J. Darr to Tyler is that of natural mother. She resides alone. 7. Plaintiffs have not participated as a party or witness, or in any other capacity, in other litigation concerning the custody of Tyler in this or another court. The Plaintiffs have no information of a custody proceeding concerning the custody of Tyler in this or any other court. The Plaintiffs do not know of a person not a party to the proceedings who has physical custody of Tyler or claims to have custody or visitation rights with respect to Tyler. $. The best interests and permanent welfare of Tyler will be served best by granting the relief requested because: a) The Plaintiffs have cared for and lived with Tyler since Apri17, 2006; b) The Plaintiffs provide Tyler with a home with adequate moral, emotional and physical surroundings as required to meet Tyler's needs; c) The Plaintiffs are, and have always been, willing to accept custody of Tyler; d) The Plaintiffs continue to exercise parental duties and responsibilities and enjoys the love and affection of Tyler; e) The Plaintiffs provide a more stable home environment; f) The Plaintiffs have assumed a stature like that of parents in the eyes of Tyler; and g) The Plaintiffs stand in loco parentis to Tyler. 9. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of Tyler has been named as parties to this action. There are no other persons who are known to have or claim a right to custody or visitation of Tyler. 10. Plaintiff requests that the following temporary order be entered: Plaintiffs and Defendants shall share legal custody of Tyler J. Querry. Plaintiffs shall have primary physical custody with the Defendants having periods of partial custody at such times the parties can mutually agree. WHEREFORE, Plaintiffs respectfully request Your Honorable Court grant them primary physical custody and shared legal custody of Tyler J. Querry. Respectfully submitted, KNIGHT & ASSOCIATES, P.C. Sean M. Shultz, Esquire Attorney ID No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17015 (717) 249-5373 Attorney for Plaintiffs VERIFICATION We verify that the statements made in the foregoing Complaint are true and correct to the best of our knowledge, information and belief. We understand that false statements herein are made subject to the penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsification to authorities. ___.~. ---..~ V~ ~~~~~ Pamela J. Verdier 1/ ~ ~ n =- e ...... ~ .,,, o a `~ f t ~, ~~ C„~3 k ....3 ~,- ~~~ {~~, z Nf 4,R •y J' 1 st ~~ -.{ L JAMES E. VERDIER AND PAMELA J. IN THE COURT OF COMMON PLEAS OF VERDIER PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. JASON FARNER AND ANGELINA J. DARK DEFENDANT • 07-2914 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, May 24, 2007 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. ,the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, June Z1, 2007 at 10:30 AM for aPre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children ale five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Hubert X. Gtlro Es . Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with. the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must he made at least 72 hours prior to any hearing or business before the court. You must attend. the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR. ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN A"T1'ORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland Countv Bar Association 32 South Bedford Street Carlisle, Pennsylvania i 7013 Telephone (717) 249-3166 ~ ~ ~ ,,, f,,,,,, ~o~, ~v-.sus ~~ - e~, ...-' .. - ..,~~ll ~ OWN 162007 JAMES E. VERDIER AND PAMELA J. IN THE COURT OF COMMON PLEAS OF VERDIER, :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v CIVIL ACTION -LAW JASON FARMER AND ANGELINA J. DARK, NO. 2007-2914 Defendant IN CUSTODY COURT ORDER ,~ AND NOW, this ~ day of June, 2007, the Conciliator being advised the parties have reached an agreement, the Conciliator relinquishes jurisdiction. ~Iubert X. Custody C ;Esquire F:\FILES\General\Current\12311\VERDIER V FANERDARR Conciliatlon Order nlinqubhhaE jurh~diMion.wpd C? c ^' i y ~ ,,-:.. . ~: , ~_i,~ , ~~ ? '-J F~ ~ ~- ~.:~ j' -__ ~! C_ J ~ . __ ~~ ~~ ~ _ ,, . . s':._ -~ f`.3 -may .1:~3 .,. ~~ ~'~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES E. VERDIER and PAMELA J. VERDIER, his wife, No. 07-2914 Plaintiffs IN CUSTODY vs. JASON FARNER and ANGELINA J. DARK, CIVIL ACTION -LAW Defendants MOTION FOR ENTRY OF A FINAL ORDER AND NOW, this /'day of June, 2007, come James E. Verdier and Pamela J. Verdier, by and through their counsel, Sean M. Shultz, Esquire, and Knight & Associates, P.C., and hereby respectfully file this Motion and in support thereof aver as follows: 1. On May 15, 2007, a Complaint in Custody was filed in the above-captioned matter. 2. A Custody Conciliation was scheduled for June 21, 2007, at 10:30 a.m. before Hubert Gilroy, Esquire. 3. The parties have signed a Custody Agreement and Stipulation, the originals of which are attached hereto. F'\User Folder\Firm DocslGendocs2007\3955-lagreement.wpd WHEREFORE, Plaintiffs respectfully .request that this Honorable Court enter the attached Custody Agreement and Stipulation as a final Order and cancel the Custody Conciliation scheduled for June 21, 2007, at 10:30 a.m. KNIGHT & ASSOCIATES, P.C. ~- an M. Shultz, Esquire Attorney I.D. No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17015 (717) 249-5373 Attorney for Plaintiffs F:\User Folder\Fitm Docs\Gendocs200713955-lagreement.wpd IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES E. VERDIER and PAMELA J. VERDIER, his wife, Plaintiffs . vs. JASON FARNER and ANGELINA J. DARK, Defendants No. 07-2914 IN CUSTODY CIVIL ACTION -LAW CUSTODY AGREEMENT AND STIPULATION THIS AGREEMENT, made this ~~ k day of ~,. ~A~1,~ 2007, by and between Plaintiffs, James E. Verdier and Pamela J. Verdier, husband and wife, of 1567 Fairview Avenue, Chambersburg, Pennsylvania, hereinafter referred to as "Verdiers," and Jason Farner of 2360 Highway 87 East, Billings,-Montana, hereinafter referred to as "Father", and Angelina J. Darr of 25 Betty Nelson Court, Lot 125, Carlisle, Pennsylvania, hereinafter referred to as "Mother," or collectively referred to as "the Parties." WHEREAS, the parties desire to provide for the custody of the child, Tyler J. Querry, born Apri129, 1994, hereinafter referred to as "Tyler." 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. F:\User Folder\Fitm Docs\Gendocs2007~3955-lagrcement.wpd 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: 1. The Parties shall have shared legal custody of Tyler. 2. Verdiers shall have primary physical custody of Tyler, subject to Father and Mother's periods of custody. 3. The Parties have agreed that they can and will make custody arrangements for the holidays by mutual agreement as the holidays arise. 4. Each party agrees to keep the other apprised in writing to the Party's then current mailing address at least twenty days prior to any move of residence. 5. Neither party shall disparage the other parent to Tyler, and they shall prevent Tyler from being exposed to third parties disparaging the other party. 6. The Parties agree that this Custody Agreement and Stipulation shall be made an order of court and shall resolve the Complaint for Custody filed by Verdiers at docket number 2007-2914 Civil Term. 7. The Parties agree that this Agreement may be executed in counterpart. 8. This Agreement may be modified in writing signed by the Parties 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. ° SEAL ( ) E. Verdier Pamela J. Verdier Jason Farner (SEAL) ,(SEAL) Angelina J. Darr STATE OF PENNSYLVANIA ) :SS. COUNTY OF ; r1 ) SEAL) On the 5~ day of ~~Yl ~. , 2007 before a Notary Public, personally appeared James E. Verdier and Pamela J. Verdier, known to me to be the persons whose names are subscribed to the within document, and acknowledged that they executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and Notarial Seal. Notary P is ONWE TI F PE 'YLV Kathy R Hermbn, Note Pubic ~~ ~ 8, ~W F:\User Folder\Firm Dots\Gendocs200T3955-lagrcemmt.wpd WITNESSED BY: STATE OF MONTANA ) :SS. COUNTY OF ) On the day of , 2007, before a Notary Public, personally appeared Jason Farner, known to me to be the person whose name is subscribed to the within document, and acknowledged that he executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and Notarial Seal. Notary Public COMMONWEALTH OF PENNSYLVANIA ) :SS. COUNTY OF ) On the day of 2007, before a Notary Public, personally appeared Angelina J. Darr, known to me to be the person whose name is subscribed to the within document, and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and Notarial Seal. Notary Public F:\User Folder\Firm Docs\Gendocs200713955-lagreemem.wpd IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES E. VERDIER and PAMELA J. VERDIER, his wife, Plaintiffs vs. JASON FARNER and ANGELINA J. DARK, Defendants No. 07-2914 IN CUSTODY CIVIL ACTION -LAW CUSTODY AGREEMENT AND STIPULATION THIS AGREEMENT, made this h day of ~ ~~ 2007, by and between Plaintiffs, James E. Verdier and Pamela J. Verdier, husband and wife, of 1567 Fairview Avenue, Chambersburg, Pennsylvania, hereinafter referred to as "Verdiers," and Jason Farner of 2360 Highway 87 East, Billings, Montana, hereinafter referred to as "Father", and Angelina J. Darr of 25 Betty Nelson Court, Lot 125, Carlisle, Pennsylvania, hereinafter referred to as "Mother," or collectively referred to as "the Parties." WHEREAS, the parties desire to provide for the custody of the child, Tyler J. Querry, born Apri129, 1994, hereinafter referred to as "Tyler." 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. F:\User Folder\Fitm Dots\Gendocs200713955-lageement.wpd 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: 1. The Parties shall have shared legal custody of Tyler. 2. Verdiers shall have primary physical custody of Tyler, subject to Father and Mother's periods of custody. 3. The Parties have agreed that they can and will make custody arrangements for the holidays by mutual agreement as the holidays arise. 4. Each party agrees to keep the other apprised in writing to the Party's then current mailing address at least twenty days prior to any move of residence. 5. Neither party shall disparage the other parent to Tyler, and they shall prevent Tyler from being exposed to third parties disparaging the other party. 6. The Parties agree that this Custody Agreement and Stipulation shall be made an order of court and shall resolve the Complaint for Custody filed by Verdiers at docket number 2007-2914 Civil Term. 7. The Parties agree that this Agreement may be executed in counterpart. 8. This Agreement may be modified in writing signed by the Parties at any time without resort to the Court. • i IN WITNESS WHEREOF, the Parties have set their hands and seals the day and year first above written. WITNESSED BY: James E. Verdier <~~ F~ , '~ ~I r ~6(~ Y~'i-~ r~ STATE OF PENNSYLVANIA COUNTY OF ,(SEAL) (SEAL) Verdier f~? / ~- r ~~~ ~~- SEAL ( ) Farner (SEAL) Angelina J. Darr :SS. On the day of , 2007 before a Notary Public, personally appeared James E. Verdier and Pamela J. Verdier, known to me to be the persons whose names are subscribed to the within document, and acknowledged that they executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and Notarial Seal. Notary Public F:\User Folder\Firm Docs\Gendocs200713955-lageemeM.wpd STATE OF MONTANA ) :SS. COUNTY OF I u,CS ~o~ ) On the '~ ~ day of ~ Gt ~ , 2007, before a Notary Public, personally appeared Jason Farner, known to me to be the person whose name is subscribed to the within document, and ackn ed that he executed the foregoing for the purpose therein contained. nY K Slsr.. ~;~''"'~' SS WHEREOF, I have hereunto set my hand and Notarial Seal. ~ Y~ S ~ ,~ ~ Notary P blic ~~~~ Y~~. ~ ~'~ ~~,~ b~ .~' ~MM. E7~ ; •' ~ ~ ALTH OF PENNSYLVANIA ) :SS. COUNTY OF ) On the day of 2007, before a Notary Public, personally appeared Angelina J. Darr, known to me to be the person whose name is subscribed to the within document, and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and Notarial Seal. Notary Public F:\User Foldu\Fitm DocslGendocs200713955-1 agreement.wpd ~. ~ i ' ~ •~ ~~9 W f',' ~~, ± 1 ~ ~J; ''y ~e t ~~ ~ 9 b' ~ ~~ ~ ~ ..Rrv~" y 3 + . ~ ~':w'.` ,p , ., ice'. ~y i a Y ~, d ~ ~~YYt ~!••a~ .y.~,. }dui ~~~~iii ~ ,f. .~1"' i / r 1 F y ~ ~ ' .<R. f w ~ n ~ ~e ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES E. VERDIER and PAMELA J. VERDIER, his wife, Plaintiffs vs. No. 07-2914 IN CUSTODY JASON FARNER and ANGELINA J. DARK, Defendants CIVIL ACTION -LAW CUSTODY AGREEMENT AND STIPULATION ~.-.. THIS AGREEMENT, made this ~h day of ~,~Q., 2007, by and between Plaintiffs, James E. Verdier and Pamela J. Verdier, husband and wife, of 1567 Fairview Avenue, Chambersburg, Pennsylvania, hereinafter referred to as "Verdiers," and Jason Farner of 2360 Highway 87 East, Billings, Montana, hereinafter referred to as "Father", and Angelina J. Darr of 25 Betty Nelson Court, Lot 125, Carlisle, Pennsylvania, hereinafter referred to as "Mother," or collectively referred to as "the Parties." WHEREAS, the parties desire to provide for the custody of the child, Tyler J. Querry, born April 29, 1994, hereinafter referred to as "Tyler." WHEREAS, the parties desire the provisions of the present Custody Agreement and Stipulation to be approved by this Honorable Court and entered ~s a court order with the same force and effect as though said order had been entered after Petition, Notice and Hearing. F:\User Folder\Firm Docs\Gendocs200T3955-lagreemeM.wpd 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: 1. The Parties shall have shared legal custody of Tyler. 2. Verdiers shall have primary physical custody of Tyler, subject to Father and Mother's periods of custody. 3. The Parties have agreed that they can and will make custody arrangements for the holidays by mutual agreement as the holidays arise. 4. Each party agrees to keep the other apprised in writing to the Party's then current mailing address at least twenty days prior to any move of residence. 5. Neither party shall disparage the other parent to Tyler, and they shall prevent Tyler from being exposed to third parties disparaging the other party. 6. The Parties agree that this Custody Agreement and Stipulation shall be made an order of court and shall resolve the Complaint for Custody filed by Verdiers at docket number 2007-2914 Civil Term. 7. The Parties agree that this Agreement may be executed in counterpart. 8. This Agreement may be modified in writing signed by the Parties 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. WITNESSED BY: James E. Verdier ~ (SEAL) Pamela J. Verdier Jason Farner .(SEAL) (SEAL) (SEAL) Angel' J. Darr STATE OF PENNSYLVANIA ) :SS. COUNTY OF ~l~,y~C, ~~ ~ ) On the ~~ day of ~~N~ , 2007 before a Notary Public, personally appeared James E. Verdier and Pamela J. Verdier, known to me to be the persons whose names are subscribed to the within document, and acknowledged that they executed the foregoing for the purpose therein contained. IN WITNESS .WHEREOF, I have hereunto set my hand and Notarial Seal. ~ v~-ti_. Notary Pu lic MMONWEALTH OF PENN~yI,ygNJA Notarial Seal ry Cham~bs sbu~ Boro, Fra~nkltn County My Commiaaion Expires May 18, 2009 F:1User FolderlFirtn Dots\Gendocs2007~3955-lageementwpd STATE OF MONTANA ) :SS. COUNTY OF ) On the day of , 2007, before a Notary Public, personally appeared Jason Farner, known to me to be the person whose name is subscribed to the within document, and acknowledged that he executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and Notarial Seal. Notary Public COMMONWEALTH OF PENNSYLVANIA ) :SS. COUNTY OF ~I~r't ~ ~ n ) On the ~ day of ~, 2007, before a Notary Public, personally appeared Angelina J. Darr, known to me to be the person whose name is subscribed to the within document, and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and Notarial Seal. ~1 Notary P lic COMMONWEALTH OF PENNSYLVANIA Notarial Seal- Kathy R. Harmon, Notary Public Chambersburg Boro, Franklin County My Commission i=xa9~p~ May 18, 2009 F\User FolderlFirm Docs\Gendocs2t10713955-lageement.wpd IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES E. VERDIER and PAMELA J. VERDIER, his wife, Plaintiffs vs. JASON FARNER and : ANGELINA J. DARK, Defendants No. 07-2914 IN CUSTODY CIVIL ACTION -LAW CERTIFICATE OF SERVICE AND NOW, this 19th day of June, 2007, I, Sean M. Shultz, Esquire, hereby certify that I have this day served the following person with a copy of the foregoing Motion for Entry of a Final Order, by first class, United States Mail, postage pre-paid, addressed as follows: Jason Farner 2360 Highway 87 East Billings, Montana 59101 Angelina J. Dan 6773 Veterans Way Ickesburg, Pennsylvania 17037 & ASSOCIATES, P.C. . -- Attorney I.D. No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17015 (717) 249-5373 Attorney for Plaintiffs F:\User Folder\Firm Docs\Gendocs2007~955-1 agreement.wpd J 1^'~ e`? Y r i .-t^.5. r_ t--~~ r ~~i •~ ^ err r,~ ~ " ~. ~' 4 duN s i zoo~''~ ~' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES E. VERDIER and PAMELA J. VERDIER, his wife, Plaintiffs vs. JASON FARMER and ANGELINA J. DARK, Defendants No. 07-2914 IN CUSTODY CIVIL ACTION -LAW ,.., L ORDER OF COURT AND NOW, this l~ day of ~a~ , 2007, based upon the attached Custody Agreements and Stipulations the following is Ordered: 1. The Parties shall have shared legal custody of Tyler J. Querry, born April 29, 1994. 2. James E. Verdier and Pamela J. Verdier shall have primary physical custody of Tyler, subject to Father and Mother's periods of custody. 3. The Parties have agreed that they can and will make custody arrangements for the holidays by mutual agreement as the holidays arise. 4. Each party agrees to keep the other apprised in writing to the party's new mailing address at least twenty days prior to any move of residence. 5. No party shall disparage any other party to Tyler, and they shall prevent Tyler from being exposed to third parties disparaging the other party. F:\User FolderlFirm Docs\Gendocs200T3955-lagreement.wpd