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HomeMy WebLinkAbout07-2913IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES E. VERDIER and No. (~' ~ ~ ~~ ~ 3 PAMELA J. VERDIER, his wife, Plaintiffs IN CUSTODY vs. MATTHEW DARK and CIVIL ACTION -LAW ANGELINA J. DARK, Defendants 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 appearance 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 maybe 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 Bar 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 (24} dias de plazo al partir de la fecha de la demanda y la notificacion. 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 notificacion y por cualguier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiendades o otros derechos importantes pars usted. LLEVE ESTA DEMANDAA UN ABOGADO IMMEDIATAMENTE. 5I 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. 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 COUNTY, PENNSYLVANIA JAMES E. VERDIER and No. O''I - o2Q/3 PAMELA J. VERDIER, his wife, Plaintiffs IN CUSTODY vs. MATTHEW DARR and ANGELINA J. DARK, Defendants CIVIL ACTION -LAW COMPLAINT FOR PRIMARY CUSTODY C~~.L`TE...~ AND NOW, this I Itk 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 Matthew Darr resides at 201 Kutz Road, Carlisle, Pennsylvania 17013, 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 Sydney Marie Darr Present Residence Awe DlOB 1567 Fairview Avenue Chambersburg, Pennsylvania 17201 10 October 12, 1998 Sydney was born out of wedlock. Sydney is presently in the physical custody of the Plaintiffs. During the past five years, Sydney has resided with the following persons and at the following addresses: a. From April 2002 to April 2005 with Defendants, Angelina's daughter, Brittany Shea and Angelina's sons, Gabriel Darr and Tyler J. Querry, at 18 Big Spring Terrace, Newville, Pennsylvania; b. From April 2005 to April, 2006 with Defendants, Angelina's daughter, Brittany Shea and Angelina's sons, Gabriel Darr and Tyler J. Querry, at 83 West Main Street, Newville, Pennsylvania; c. From April, 2006 to July, 2406 with the Plaintiffs, James Verdier's son, Eric Bailey, Plaintiff s daughter Tia Verdier and Sydney's brother, Tyler J. Querry at 1567 Fairview Avenue, Chambersburg, Pennsylvania; d. From July, 2006 to April 20, 2007 with Defendant at 25 Betty Nelson Court, Lot 125, Carlisle, Pennsylvania; and e. From Apri120, 2007 to present with the Plaintiffs, James Verdier's son, Eric Bailey, Plaintiffs' daughter, Tia Verdier and Sydney's brother, Tyler J. Querry at 1567 Fairview Avenue, Chambersburg, Pennsylvania. The mother of Sydney is Defendant, Angelina J. Darr and her current residence is 25 Betty Nelson Court, Lot 125, Cazlisle, Pennsylvania. She is married to Defendant Matthew Darr. The father of Sydney is Defendant, Matthew Darr and his current residence is 201 Kutz road, Cazlisle, Pennsylvania. He is married to Defendant Angelina J. Darr. The maternal great uncle and aunt of Sydney 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 Sydney is that of maternal great uncle and aunt. The Plaintiffs currently reside with Sydney and James Verdier's son, Eric Bailey, Plaintiffs' daughter, Tia Verdier and Sydney's brother, Tyler J. Querry. 5. The relationship of Defendant, Matthew Darr to Sydney is that of natural father. He currently resides with his father, Larry Darr, his stepdaughter, Brittany Shea, and Respondents' son, Gabriel Darr. 6. The relationship of Defendant, Angelina J. Darr to Sydney 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 Sydney in this or another court. The Plaintiffs have no information of a custody proceeding concerning the custody of Sydney 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 Sydney or claims to have custody or visitation rights with respect to Sydney. 8. The best interests and permanent welfare of Sydney will be served best by granting the relief requested because: a) The Plaintiffs have cared for and lived with Sydney since Apri120, 2007; b) The Plaintiffs provide Sydney with a home with adequate moral, emotional and physical surroundings as required to meet the Sydney's needs; c) The Plaintiffs are, and have always been, willing to accept custody of Sydney; d) The Plaintiffs continue to exercise parental duties and responsibilities and enjoys the love and affection of Sydney; e) The Plaintiffs provide a more stable home environment; f j The Plaintiffs have assumed a stature like that of parents in the eyes of Sydney; and g) The Plaintiffs stand in loco parentis to Sydney. 9. Each parent whose parental rights to Sydney have not been terminated and the person who has physical custody of Sydney 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 Sydney. 10. Plaintiff requests that the following temporary order be entered: Plaintiffs and Defendants shall shaze legal custody of Sydney Marie Darr. Plaintiffs shall have primary physical custody with Defendants having periods of partial custody at such times as the parties can mutually agree. WHEREFORE, Plaintiffs respectfully request Your Honorable Court grant them primary physical custody and shared legal custody of Sydney Marie Darr. Respectfully submitted, KNIGHT & ASSOCIATES, P 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. _ ._. _ ._...____.~ ~- E. Verdier ~~~~~~ Pamela J. Verdier l ~ ~' ~ r~ ~_~ ,~ ~ ~} ;~' V ~ ~ ~: ~~ ~ ~ -~ ~ ~ ~ =_~~ .~ ,-- ~.. -a ~ r-- rt ~-'-` ~: ,f . "~~ ~; ~; JAMES E. VERDIER AND PAMELA J. [N THE COURT OF COMMON PLEAS OF VERDIER PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA. V' 07-2913 CIVIL ACTION LAW MATTHEW DARR AND ANGELINA J. DARR IN CUSTODY DEFENDANT ORllER 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 21, 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 pcr-nanent 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. Gilro Es . Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act oI' 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our ottice. A11 arrangements must be 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 ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FOR"I'H BELOW "CO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ! ,i,.~ ~ ~~- ~ ~'°~~I~ co -s~~ ,. ; .. r-, -. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES E. VERDIER and PAMELA J. VERDIER, his wife, Plaintiffs vs. MATTHEW DARK and ANGELINA J. DARK, Defendants No. 07-2913 IN CUSTODY CIVIL ACTION -LAW MOTION FOR ENTRY OF A FINAL ORDER AND NOW, this ~ ~S~`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\Fum Docs\Gendocs200'T1~955-2agreemeM.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. can 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\Firtn Docs\Gendocs2Q0713 9 5 5-2agreement.wpd IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES E. VERDIER and PAMELA J. VERDIER, his wife, Plaintiffs vs. MATTHEW DARR and ANGELINA J. DARK, Defendants No. 07-2913 IN CUSTODY CIVIL ACTION -LAW CUSTODY AGREEMENT AND STIPULATION THIS AGREEMENT, made this ~-% day of~~LJI.G 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 Matthew Darr of 201 Kutz Road, Carlisle, Pennsylvania, 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, Sydney Marie Darr, born October 12, 1998, hereinafter referred to as "Sydney." 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 Foldtt\Firm Dots\Gendocs200T3955-2agreement.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 Sydney. 2. Verdiers shall have primary physical custody of Sydney, subject to Father and Mother's periods of partial 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 Sydney, and they shall prevent Sydney 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 2007-2913 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. F:\User FoIdeRFirm Does\Gendocs200T3955-2agreement.wpd IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES E. VERDIER and PAMELA J. VERDIER, his wife, Plaintiffs vs. MATTHEW DARK and ANGELINA J. DARR, Defendants No. 07-2913 IN CUSTODY 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 15b7 Fairview Avenue, Chambersburg, Pennsylvania, hereinafter referred to as "Verdiers," and Matthew Darr of 201 Kutz Road, Carlisle, Pennsylvania, 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, Sydney Marie Darr, born October 12, 1998, hereinafter referred to as "Sydney." 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:1User FolderlFirm Docs\Gendocs2007\3955-2agreement.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 Sydney. 2. Verdiers shall have primary physical custody of Sydney, subject to Father and Mother's periods of partial 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 Sydney, and they shall prevent Sydney 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 2007-2913 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. F:\Uxr Folder\Firm Docs\Gendocs2007\3955-2agreement.wpd IN WITNESS WHEREOF, the Parties have set their hands and seals the day and year first above written. WITNESSED BY: James E. Verdier (SEAL) (SEAL) Pamela J. Verdier (SEAL) M tthew Darr Angelina J. Darr STATE OF PENNSYLVANIA ) :SS. COUNTY OF ) (SEAL) 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 Foldu\Firm Docs\Gendocs2007\3955-2ageement.w+pd IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES E. VERDIER and PAMELA J. VERDIER, his wife, Plaintiffs vs. No. 07-2913 IN CUSTODY MATTHEW DARK and ANGELINA J. DARK, Defendants CIVIL ACTION -LAW CUSTODY AGREEMENT AND STIPULATION -}~ ~ THIS AGREEMENT, made this 1 ~ day of ~ (,~i(ti,~ 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 Matthew Darr of 201 Kutz Road, Carlisle, Pennsylvania, 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, Sydney Marie Darr, born October 12, 1998, hereinafter referred to as "Sydney." 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:Wser Folder\Firm Docs\Gendocs200713955-2agreement.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 Sydney. 2. Verdiers shall have primary physical custody of Sydney, subject to Father and Mother's periods of partial 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 parry 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 Sydney, and they shall prevent Sydney 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 2007-2913 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. F~\User Folder\Firm DotslGendocs200T3955-2agreemem.wpd IN WITNESS WHEREOF, the Parties have set their hands and seals the day and year first above written. WITNESSED BY: .(SEAL} James E. Verdier (SEAL) Pamela J. Verdier (SEAL) Matthew Dan Ca~~ (SEAL) Ange ina J. Darr STATE OF PENNSYLVANIA ) :SS. COUNTY OF ~~ ~i"lJ K l 1 iV ) On the ~`-~'1 day of Jw-~.~.., , 200? 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 Pu c COMMONVyEgI,TH F PENNSYLV Notarial Seal Kathy R. Ham~bn, Notarryy Public Chambersburg Boro, FranR{in Cou My Commission Sxpires May 18, 20 0 F~\User Folder\Firm Dots\Gendocs200T3955-2agreement.wpd -~ ! } f STATE OF PENNSYLVANIA ) :SS. COUNTY OF CUMBERLAND ) On the day of , 2007, before a Notary Public, personally appeared Matthew Darr, 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 ~(L~-~ ~(.,L ~ ~ ) On the ~ day of ~~e, , 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 P ~ lic COMMONWEALTH OF PENNSYLVANIA Notarial Seal Kathy R. Harmon, Notary Public Chambarsburg l3oro, Franklin County My Commission Expires May 18, 2009 F:\User Folde~Firm Docs\Gendocs200713955-2agreemem.wpd IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES E. VERDIER and PAMELA J. VERDIER, his wife, KNIGHT & ASSOCIATES, P.C. Plaintiffs vs. MATTHEW DARK and ANGELINA J. DARR, Defendants No. 07-2913 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: Matthew Darr 201 Kutz Road Carlisle, Pennsylvania 17013 Angelina J. Darr 6773 Veterans Way Ickesburg, Pennsylvania 17037 F:\User Folder\Firm Docs\Gendocs200713955-2agreemem.wpd Attorney I.D. No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17015 (717) 249-5373 Attorney for Plaintiffs i~ .~ .~ --~ ' . ~ r,,,_,_` _ _~ ~R ... ..~ i-..,.,p -. _, ...~,. t..- ~M JUN 811D01,~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES E. VERDIER and PAMELA J. VERDIER, his wife, Plaintiffs vs. MATTHEW DARK and ANGELINA J. DARR, Defendants No. 07-2913 IN CUSTODY CIVIL ACTION -LAW ORDER OF COURT AND NOW, this ~ day of , 2007, based upon the attached Custody Agreements and Stipulations the following is Ordered: 1. The Parties shall have shared legal custody of Sydney Marie Darr, born October 12, 1998. 2. James E. Verdier and Pamela J. Verdier shall have primary physical custody of Sydney, 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 Sydney, and they shall prevent Sydney from being exposed to third parties disparaging the other party. F:\User Folder\Firtn Docs\Gendocs2007\3955-2agreement.wpd