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Home My WebLink About01-6257WILLIAM HOLST1NE and KATHIANN HOLSTINE, Plaintiffs/Petitioners VS. TIM078 Y RAYMOND GREENE, Defendant/Respondent AND NOW, this IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. Civil Action - Custody CUSTODY AGREEMENT · day of ggL4/~g~a/''-' 2001 come the parties, William C. Holstine and Kathiann Holstine, by and through their counsel, Steven C. Courtney and Metzger, Wickersham, Knauss & Erb, P.C., and requests this Honorable Court enter the attached Order for the following reasons: WHEREAS, Timothy Raymond Greene is the natural father of Michael Ryan Greene (DOB 2/29/00); WHEREAS, Timothy Raymond Greene was given majority physical custody of Michael Ryan Greene as evidenced by the Custody Consent Decree attached hereto as Exhibit "A". WHEREAS, William C. Holstine, (hereinafter referred to as "GRAND-FATHER") and Kathiann Holstine, (hereinafter referred to as "GRAND-MOTHER") are the natural grand-parents of Michael Ryan Greene (DOB 2/29/00); and WHEREAS, Father, Grand-Father and Grand-Mother desire to make arrangements for the custody and visitation of the said minor child; and, WHEREAS, both parties have been advised by counsel or have had the opportunity to be advised by counsel; and, Document #: 216625. I WHEREAS, the parties intend to submit this Custody Agreement to the Court of appropriate jttrisdiction for incorporationand merger into a Court Order approving said Agreement; NOW, THEREFORE, it is hereby stipulated and agreed as follows: 1. The Petitioner, WILLIAM C. HOLSTINE, is an adult individual residing at 821 Bower Road, Shermansdale, Perry County, Pennsylvania 17090. 2. The Petitioner, KATHIANN HOLSTINE, is an adult individual residing at 821 Bower Road, Shermansdale, Perry County, Pennsylvania 17090. 3. The Respondent, TIMOTHY RAYMOND GREENE, is an adult individual residing at 307B North Bedford Street, Carlisle, Cumberland County, Pennsylvania 17013. 4. For the past five (5) years, the minor child has resided with the following persons at the following addresses: Name Timothy Raymond Greene Address Dates 307B North Bedford St. 6/01 to Carlisle, PA 17013 present RR1 2/01 to Landisburg, PA 6/01 Fort Stewart, Georgia 7/98 to 2/01 5. The Mother of the child is Jennifer O'Neil Stancil Greene, who resides at 972 Bright Road, While Plains, VA 23893. 6. The Father of the child is Timothy Raymond Greene, who resides at 307B North Bedford Street, Carlisle, Pennsylvania 17013. Document ii: 216625.1 7. The relationship of Petitioners to the minor child is that of Grand-Father and Grand- Mother. Petitioners currently resides with the following persons. Name Relationship William C. Holstine Self Kathiann Holstine Self g. The relationship of Respondent to the minor child is that of Father. Respondent currently resides with the following persons: Name Relationship Timothy Raymond Greene self 9. Micheal Ryan Greene is presently in the custody of Grand-Father and Grand-Mother, who resides at 821 Bower Road, Shermansdale, Perry County, Pennsylvania 17090. 10. Grand-Father and Grand-Mother shall have majority physical custody of the minor child, and FATHER shall have minority physical custody. 11. Grand-Father and Grand-Mother and Father will have shared legal custody of MICHAEL RYAN GREENE. Father shall have time with the minor child upon such date and times as agreed by the parties. 12. Both parties shall permit liberal telephone calls to the minor child from the non- custodial parent. 13. The parties agree to cooperate with one another in the implementation of the aforesaid Agreement and understand and agree that other changes or modifications in the aforesaid schedule and/or times specified may be necessary to enable both parents to continue to foster and develop a Document #: 216625.1 good and healthy relationship with the children. To that end, the parties agree to cooperate with one another to encourage the relationship of the children with the other parent and agree to refrain from any and all conduct, activity, or communication which would adversely affect the children's relationship with either parent. 14. Upon the knowledge of pending relocation, temporary or permanent, of either parent, each parent must immediately inform the other of his/her new address and telephone number. 15. Both parties shall utilize child restraint seats and seat belts while transporting the child by automobile. 16. This Agreement shall be effective immediately upon signature by both parties and its validity is not contingent upon Court approval. Date:/d -- / "t7 [ Date: /~9 - O1 - O/ Date: William c. Holstine, Plaintiff K/tthiann Holstine, l~laintiff ~othy Raymond ~reene, Defendant Document #: 216625. I COMMONWEALTH OF PENNSYLVANIA : : SS COUNTY OF : Personally appeared before me, a notary public in and for said Commonwealth and County, the undersigned, WILLIAM C. HOLSTINE and KATHIANN HOLSTINE, Plaintiffs, who, being duly sworn according to law, deposes and says that they are the GRANDPARENTS and that the facts set forth in the within Custody Agreement are tree and correct to the best of his knowledge, information, and belief. Sworn to and subscribed before melthis I day ~ ~ - j2001. No~T~ublic · ' c~f William C. Holstine, Plaintiff K~thi~tnn Holstine, Plainiiff Document ii: 208229.1 COMMONWEALTH OF PENNSYLVANIA : : SS COUNTY OF : Personally appeared before me, a notary public in and for said Commonwealth and County, the undersigned, TIMOTHY RAYMOND GREENE, Defendant, who, being duly sworn according to law, deposes and says that he is the FATHER and that the facts set forth in the within Custody Agreement are tree and correct to the best of her knowledge, information, and belief. Sworn to and sul?scribed bef~ore me] this ~ day · ,2001. Notary Public ~// T~imothy Raymond Greene, Defendant My Comm~ Document #: 208229.1 WILLIAM C. HOLSTINE, KATHIANN HOLSTINE, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TIMOTHY RAYMOND GREENE, : NO. 2001-6257 CIVIL TERM Defendant : : CIVIL ACTION - CUSTODY ORDER OF COURT AND NOW, this 9TM day of NOVEMBER, 2001, Jennifer O'Neil Stancil Greene, is added as a par~y defendant in this action. Plaintiff's counsel is directed to serve her with a copy of all pleadings and notice of the upcoming heating. CC: Steven C. Courtney, Esquire Jennifer O'Neil Stancil Greene 972 Bright Road White Plains, Virginia 23893 Timothy R. Greene 307B North Bedford Street Carlisle, Pa. 17013 Edward E. Guili J :sld PENNSYLtZ~,N~,A WILLIAM C. HOLSTINE, KATHIANN HOLSTINE, Plaintiffs VS. TIMOTHY RAYMOND GREENE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION- LAW : : 0 R D E R OF COURT A Custody Agreement has been filed in the Court of Common Pleas of Cumberland County concerning custody, partial custody and visitation of Michael Ryan Greene. The Court has learned you may have a legal interest in custody, partial custody or visitation of the child named. A heating will be held in Courtroom ,~ of the Court ofco~jn. 0n Pleas, One Courthouse Square, Carlisle, Pennsylvania 17013 on ~~,'~t ~.If you wish to have custody, partial custody or visitation of the child 5r wish to present evidence to the Court on those matters, you should appear at the place and time and on the date above. If you have the child in your possession or control, you must appear and bring them to the Courthouse with you. If you wish to claim the right of custody, pm~tial custody or visitation, you may file a counterclaim. If you fail to appear as provided by this Order or to bring the child, an Order for custody, partial custody or visitation may be entered against you or the Court may issue a warrant for your arrest. The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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 be made at least 72 hours prior to any heating or business before the court. You must attend the scheduled conference or hearing. 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. Document #: 219913.1 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, Pennsylvania 17013-3387 PHONE: (717) 249-3166 WILLIAM C. HOLSTINE, KATHIANN HOLSTINE, Plaintiffs VS. TIMOTHY RAYMOND GREENE, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 2001-6257 AFFIDAVIT OF SERVICE I, Steven C. Courtney, counsel for Plaintiff, hereby certify that a tree and correct copy of the Complaint for Custody and Order was served upon the following, by certified mail, return receipt and regular mail on November 19, 2001. Jennifer O'Neil Stancil 972 Bright Road White Plains, VA 23893 Timothy Greene 307B North Bedford Street Carlisle, Pennsylvania 17013 Date: . SAUSS P.C. Steven C- ~geo~, Es"q~ ) ID. No. 7~fo69 -- 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorney for Plaintiff Document #: 221591,1 WILLIAM C. HOLSTINE, KATHIANN HOLSTINE, Plaintiffs TIMOTHY RAYMOND GREENE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-6257 CIVIL TERM CIVIL ACTION - CUSTODY ORDER OF COURT AND NOW, this 20th day of December, 2001, after hearing, the parties are granted shared legal custody of Michael Ryan Greene. Primary physical custody is awarded to the paternal grandparents, William C. Holstine and Kathiann Holstine. Mother and Father shall be entitled to partial physical custody and/or visitation as agreed upon. By the Court, Edward E Guido, J. Steven C. Courtney, Esquire Attorney for Plaintiffs Jennifer O'Neil Stancil Greene 972 Bright Road White Plains, VA 23893 Timothy R. Greene 307-B North Bedford Street Carlisle, PA 17013 srs