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HomeMy WebLinkAbout07-7366 STEPHANIE A. COOPER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN CUSTODY PAUL R. COOPER, : Defendant. : NO. 07 - 7L, CIVIL TERM NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, you may lose rights and visitation of your Children. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford St. Carlisle, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 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 hearing or business before the court. You must attend the scheduled conference or hearing. STEPHANIE A. COOPER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vi. : CIVIL ACTION - LAW IN CUSTODY PAUL R. COOPER, Defendant. :NO. c7,7- 73 4- G CIVIL TERM COMPLAINT FOR CUSTODY The Plaintiff, Stephanie A. Cooper, by her attorneys, the Family Law Clinic, sets forth the following cause of action in custody. 1. The Plaintiff is Stephanie A. Cooper, who currently resides at 1055 Nanroc Drive, Mechanicsburg, 17055, Cumberland County, Pennsylvania. 2. Defendant is Paul R. Cooper, who currently resides at 408 Centerview Avenue, New Cumberland, 17070, York County, Pennsylvania. 3. Plaintiff seeks primary custody o£ Name Present Residence Age Anthony R. Cooper 1055 Nanroc Drive, 12 Mechanicsburg, Cumberland County, Pennsylvania, 17055 Darian A. Cooper 1055 Nanroc Drive, 10 Mechanicsburg, Cumberland County, Pennsylvania, 17055 The Children are presently in the custody of Stephanie A. Cooper, who resides at 1055 Nanroc Drive, Mechanicsburg, 17055, Cumberland County, Pennsylvania. During the past five years the Children has resided with the following persons at the following addresses: Persons Address Dates Stephanie A. Cooper 1055 Nanroc Drive 3/6/06-12/3/07 Mechanicsburg, Cumberland County, Pennsylvania, 17055 Stephanie A. Cooper 182 Peach Street 9/6/03-3/6/06 Paul R. Cooper Lemoyne, Cumberland County, Pennsylvania Stephanie A. Cooper Keystone Inn 3/6/02-9/6/03 Paul R. Cooper New Cumberland, York County, Pennsylvania The mother of the Children is Stephanie A. Cooper. She is married to Paul R. Cooper. The father of the Children is Paul R. Cooper. He is married to Stephanie A. Cooper. 4. The relationship of Plaintiff to the Children is that of mother. The Plaintiff currently resides with the following persons: Name Anthony R. Cooper Darian A. Cooper Relationship Son Son 5. The relationship of defendant to the Children is that of father. The defendant currently resides with the following persons: Name Hedwig Cooper Guy Cooper Relationship Mother Father 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the Children in this or another court. Plaintiff has no information of a custody proceeding concerning the Children pending in a court of this Commonwealth, or any other state. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the Children or claims to have custody or visitation rights with respect to the Children. 7. The best interest and permanent welfare of the Children will be served by granting the relief requested because: a. Plaintiff has been the Children's primary caretaker for all of the Children's lives; b. Plaintiff provides the Children with a stable home and environment with adequate moral, emotional, and physical surroundings as required to meet the Children's needs; c. Plaintiff has permitted contact between Defendant and the Children and will continue to do so; d. Plaintiff is willing to accept custody of the Children. 8. Each parent whose parental rights to the Children have not been terminated and the person who has physical custody to the Children have been named as parties to this action. WHEREFORE, Plaintiff requests the Court to grant her shared legal custody and primary physical custody of the Children, with the father having periods of partial physical custody. Date: l02 16 /Zoo _? THOMAS M. PLACE ROBERT E. RAINS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 Respectfully submitted, I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the pee lties of 1 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Stephanie A. Cooper C`-' r•-.a _, tJ _. ? -n r--? ---? _ ?-i r? ? i ?' ?- 'n ? ; ;„ .. , ?, -, c. , __ = _ _ ---- r - fi r? ``s STEPHANIE A. COOPER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN CUSTODY PAUL R. COOPER, Defendant. : NO. 67 -'r3GL CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Stephanie A. Cooper, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date /'? 6 '2 6'? ROBERT E. RAINS ° THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street. Carlisle, PA 17013 717-243-2968 717-243-3639 ? C J :.... STEPHANIE A. COOPER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : IN CUSTODY PAUL R. COOPER, Defendant. :NO. --'Y3L(c- CIVIL TERM CUSTODY AGREEMENT THIS AGREEMENT, made this day o , 2007 between Stephanie A. Cooper , hereinafter Mother, and Paul R. Cooper, hereinafter Father, concerns the custody of their children: Anthony R. Cooper, born April 25, 1995 and Darian A. Cooper, born August 15, 1997. Mother and Father desire to enter into an agreement as to the custody of the children. Mother and Father agree to the following: 1. Mother and Father shall share legal custody of the children. 2. Mother shall have and primary physical custody of the children. 3. Father shall have supervised partial physical custody of only one child per weekend: each child is permitted to go to Father's residence every other weekend, but never both children during one weekend. Children's paternal Grandparents shall supervise all of Father's visits with the children at Father's residence. Father's partial custody of each child shall be from Friday at 5:00 p.m. through Sunday at 2:00 p.m. Father shall call Mother in advance before each child is permitted to go to Father's residence. Mother shall be notified before each child is permitted to be at Father's residence if Paternal Grandparents' supervision of the child is not possible. Partial physical custody of each child shall depend on when the Paternal Grandparents can supervise the child. 4. Father shall not be intoxicated, under the influence of illegal drugs, or violent while he is with the children. He must continue taking his prescribed medication. Father shall not in any way place the children in fear of physical or mental harm or distress. 5. Mother will have both children on Christmas Day and Easter. Father will have both children on Christmas Eve from 9:00 a.m. to 9:00 p.m. Mother and Father will agree upon which remaining holidays each child will spend with each parent. 6. Mother and Father will agree upon drop off and pick up times and locations. 7. When each child is at Father's residence, the child shall receive the following as a minimum standard of care: a. Proper and Adequate Nutrition: each child shall receive, at a minimum, three (3) full meals. Each meal shall have proper and adequate nutrition. Each child shall receive at least one healthy snack during the day along with either a juice or water with each meal and snack. b. Proper and Adequate Cleanliness: each child shall have at least one shower or bath per day, including proper shampooing of hair. Each child shall have his teeth and hair brushed at least once per day and at the time of the shower or bath. c. Proper and Adequate Supervision: each child shall ALWAYS be supervised by his paternal grandparents, whether they are inside or outside of Father's residence. 8. Mother and Father will notify each other of all medical care the children receive while in that parent's care. Mother and Father will notify the other immediately of medical emergencies which arise while the children are in that parent's care. 9. Neither parent shall do anything which may estrange the children from the other party, or injure the opinion of the children as to the other parent or which may hamper the free and natural development of the children's love and respect for the other parent. 10. Father acknowledges that the Family Law Clinic represents only Mother's interest in this matter and has given him no legal advice other than that he should seek the advice of legal counsel. 11. The parties intend to be bound by the terms of this agreement and intend for this Agreement to be made an Order of Court. &KV2-V-- Stephanie A. Cooper, Plaintiff aul R. Co r, Defendant f Witness Witness Marc Aouxt. Certified Legal Intern Counsel for Plaintiff ROBERT E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Counsel for Plaintiff FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717)243-2968 Fax (717)243-3639 r-_a ?? :? , :u , ?? -r'! ?' ? i it t JE ?? _ - ;? ..„? ..;? :.- ,' y? __ ' ? : =+ ?? "? •-- r.a ? ? STEPHANIE A. COOPER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN CUSTODY PAUL R. COOPER, Defendant. : NO.0-7?Lb CIVIL TERM 0*day CUSTODY ORDER AND NOW, thist of. 4444*4641 , 2007, the following Order is entered by consent of the parties with regard to custody of the parties' minor children, Anthony R. Cooper, born April 25, 1995 and Darian A. Cooper, born August 15, 1997. As per the attached and signed custody agreement, the following terms are approved and entered as an order of court: 1. Mother and Father shall share legal custody of the children. 2. Mother shall have and primary physical custody of the children. 3. Father shall have supervised partial physical custody of only one child per weekend: each child is permitted to go to Father's residence every other weekend, but never both children during one weekend. Children's paternal Grandparents shall supervise all of Father's visits with the children at Father's residence. Father's partial custody of each child shall be from Friday at 5:00 p.m. through Sunday at 2:00 p.m. Father shall call Mother in advance before each child is permitted to go to Father's residence. Mother shall be notified before each child is permitted to be at Father's residence if Paternal Grandparents' supervision of the child is not possible. Partial physical custody of each child shall depend on when the Paternal Grandparents can supervise the child. 4. Father shall not be intoxicated, under the influence of illegal drugs, or violent while he is with the children. He must continue taking his prescribed medication. Father shall not in any way place the children in fear of physical or mental harm or distress. 5. Mother will have both children on Christmas Day and Easter. Father will have both children on Christmas Eve from 9:00 a.m. to 9:00 p.m. Mother and Father will agree upon which remaining holidays each child will spend with each parent. 6. Mother and Father will agree upon drop off and pick up times and locations. 7. When each child is at Father's residence, the child shall receive the following as a minimum standard of care: a. Proper and Adequate Nutrition: each child shall receive, at a minimum, three (3) full meals. Each meal shall have proper and adequate nutrition. Each child shall receive at least one healthy snack during the day along with either a juice or water with each meal and snack. b. Proper and Adequate Cleanliness: each child shall have at least one shower or bath per day, including proper shampooing of hair. Each child shall have his teeth and hair brushed at least once per day and at the time of the shower or bath. c. Proper and Adequate Supervision: each child shall ALWAYS be supervised by his paternal grandparents, whether they are inside or outside of Father's residence. 8. Mother and Father will notify each other of all medical care the children receive while in that parent's care. Mother and Father will notify the other immediately of medical emergencies which arise while the children are in that parent's care. 9. Neither parent shall do anything which may estrange the children from the other party, or injure the opinion of the children as to the other parent or which may hamper the free and natural development of the children's love and respect for the other parent. 10. Father acknowledges that the Family Law Clinic represents only Mother's interest in this matter and has given him no legal advice other than that he should seek the advice of legal counsel. 11. The parties intend to be bound by the terms of this agreement and intend for this Agreement to be made an Order of Court. J. YWA NN,3d )UNPICK) 74',f lQ39 " 9 0 =1 Wd h 1 330 LOOZ ,1WIONUHiUd 3Hl 3O 3ai-C?-Q31H Stephanie A. Cooper, NOW Stephanie Armstrong Plaintiff V. Paul R. Cooper, Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY : NO. 07- 7366 CIVIL TERM PETITION TO MODIFY CUSTODY ORDER 1. The petition of Stephanie A. Cooper, now Stephanie Armstrong, through her attorneys, the Family Law Clinic, respectfully represents that on December 14, 2007, an Order of Court was entered for custody of Anthony Cooper, born April 25, 1995, and Darian Cooper, born August 15, 1997, a true and correct copy of which is attached. Under the existing Order of Court, Plaintiff, Stephanie Cooper, now Stephanie Armstrong, (Mother) has primary physical custody of Anthony and Darian Cooper (Children). Defendant, Paul Copper (Father) has supervised partial custody of Children. Father is to have physical custody of one child each weekend from Friday at 5:00 p.m. until Sunday at 2:00 p.m. The Order states that because both children have developmental disabilities, including autism, and Father suffers from mental illness, it is unsafe for Father to have custody of both children at the same time. Children's Paternal Grandparents (Grandparents), who share a home with Father, are to supervise all visits between Father and Children. Father is not to be intoxicated, under the influence of illegal drugs, or violent while he is with Children. 2. This Order should be modified because: a. Father has an extensive history of mental illness including Schizophrenia, Bipolar Disorder, and Multiple Personality Disorder. Father is also a self mutilator and has injured himself in front of Children. During the past several months, Father's illness has worsened and his behavior has become more erratic. c. Mother believes and therefore avers that Father drinks alcohol to the point of intoxication when in the presence of Children. d. Mother believes and therefore avers that Father smokes marijuana when in the presence of Children. f. Mother believes and therefore avers that Grandparents have failed to adequately supervise Father's visits with Children. g. One of the children, Darian, has severe breathing problems, including asthma and allergies. h. Mother believes and therefore avers that the condition of Grandparents' home exacerbates Darian's breathing difficulties. In the past year, Grandparents have acquired approximately ten dogs of varying breeds to be kept in their home as pets. These dogs urinate and defecate in the home on towels. Several members of Grandparents' household also smoke inside home while in Darian's presence. 3. In light of the factors stated above, modification of the Custody Order is in the best interests of Children. WHEREFORE, Petitioner asks that the Court modify the existing Order for Custody and grant Mother sole legal and physical custody. Mother asks that Father be granted visitation as the parties agree, that visits between the children and Father be supervised by Father's brother Michael Cooper, and that the visits take place at the Capital City Mall in Camp Hill, Pennsylvania. Date: \°? 6 )N' Nicole Berman Certified Legal Intern c?L?sQ THOM CE ROBERT RAINS ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in this petition are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. § 4904 relating to unworn falsification to authorities. Date: Stephanie Armstrong 3 STEPHANIE A. COOPER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN CUSTODY PAUL R. COOPER, Defendant. : NO.0-7CIVIL TERM CUSTODY ORDER AND NOW, this/ gtay of, 2007, the following Order is entered by consent of the parties with regard to custody of the parties' minor children, Anthony R. Cooper, born April 25, 1995 and Darian A. Cooper, born August 15, 1997. As per the attached and signed custody agreement, the following terms are approved and entered as an order of court: 1. Mother and Father shall share legal custody of the children. 2. Mother shall have and primary physical custody of the children. 3. Father shall have supervised partial physical custody of only one child per weekend: each child is permitted to go to Father's residence every other weekend, but never both children during one weekend. Children's paternal Grandparents shall supervise all of Father's visits with the children at Father's residence. Father's partial custody of each child shall be from Friday at 5:00 p.m. through Sunday at 2:00 p.m. Father shall call Mother in advance before each child is permitted to go to Father's residence. Mother shall be notified before each child is permitted to be at Father's residence if Paternal Grandparents' supervision of the child is not possible. Partial physical custody of each child shall depend on when the Paternal Grandparents can supervise the child. 4. Father shall not be intoxicated, under the influence of illegal drugs, or violent while he is with the children. He must continue taking his prescribed medication. Father shall not in any way place the children in fear of physical or mental harm or distress. 5. Mother will have both children on Christmas Day and Easter. Father will have both children on Christmas Eve from 9:00 a.m. to 9:00 p.m. Mother and Father will agree upon. which remaining holidays each child will spend with each parent. 6. Mother and Father will agree upon drop off and pick up times and locations. 7. When each child is at Father's residence, the child shall receive the following as a minimum standard of care: a. Proper and Adequate Nutrition: each child shall receive, at a minimum, three (3) full meals. Each meal shall have proper and adequate nutrition. Each child shall receive at least one healthy snack during the day along with either a juice or water with each meal and snack. b. Proper and Adequate Cleanliness: each child shall have at least one shower or bath per day, including proper shampooing of hair. Each child shall have his teeth and hair brushed at least once per day and at the time of the shower or bath. c. Proper and Adequate Supervision: each child shall ALWAYS be supervised by his paternal grandparents, whether they are inside or outside of Father's residence. 8. Mother and Father will notify each other of all medical care the children receive while in that parent's care. Mother and Father will notify the other immediately of medical emergencies which arise while the children are in that parent's care. 9. Neither parent shall do anything which may estrange the children from the other party, or injure the opinion of the children as to the other parent or which may hamper the free and natural development of the children's love and respect for the other parent. 10. Father acknowledges that the Family Law Clinic represents only Mother's interest in this matter and has given him no legal advice other than that he should seek the advice of legal counsel 11. The parties intend to be bound by the terms of this agreement and intend for this Agreement to be made an Order of Court. J. N RE?? -D and In Testmc?y a Pa. ar?d se1LpA,,, ?? f ; ?a r ..,. ? :( T _ e_,?:? "Tg 1 ` i Y l L_•? + ?) ,'.'?, "j "f"1 Y -.»? _: (_' ??.w - ,, w ?c_:. ???, .. ? ?? '-r _`` ?} tdW Stephanie A. Cooper, NOW Stephanie Armstrong Plaintiff V. Paul R. Cooper Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY : NO. 07-7366 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Stephanie Armstrong, formerly Stephanie Cooper, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date 1 l fI Res r,ctfully submitted, 10i Nicole Berman Certified Legal Intern ROBER INS THOMAS M. PLACE ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 ? ?? ii ? m`??-' ? y r ? '?.,," ` ?, i, _' t ? ` C.,J ._ ? STEPHANIE A. COOPER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. PAUL R. COOPER DEFENDANT 2007-7366 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, November 21, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Monday, December 22, 2008 _ at 9:30 AM for a Pre-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. 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: lsl ac ueline M. Verne 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 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 FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 f. C, : ? Stephanie A. Cooper, NOW Stephanie Armstrong Plaintiff v. Paul Cooper, Defendant : IN THE COURT OF CUMBERLAND CC 4ON PLEAS OF , PENNSYLVANIA CIVIL ACTION - LA IN CUSTODY NO. 07-7366 F I, Nicole Berman, Certified Legal Intern, Family Law true and correct copies of the Petition to Modify Custody and by depositing a copy of the same in the United States mail to Cumberland, Pennsylvania 17070 on December 16, 2008. Nicole B Certified TERM , hereby certify that I served of Court on Paul R. Cooper, Centerview Avenue, New Intern FAMIL LAW CLINIC 45 North Pitt Street Carlisle, A 17013 (717) 241-2968 Fax: (717) 243-3639 ...? ?) ?, ?? .? Stephanie A. Cooper, : IN THE COURT OF COMMON PLEAS OF NOW Stephanie Armstrong : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : CIVIL ACTION - LAW IN CUSTODY Paul Cooper, Defendant : NO. 07-7366 CIVIL TERM CUSTODY AGREEMENT THIS AGREEMENT, made this a; day of 2008, between Stephanie A. Cooper, now Stephanie Armstrong, hereinafter Mother, and Paul R. Cooper, hereinafter Father, concerns the custody of their children: Anthony Cooper, born April 25, 1995 and Darian Cooper, born August 15, 1997. Mother and Father desire to enter into an agreement as to the custody of the children. Mother and Father agree to the following. 1. Mother and Father shall share legal custody of the children. 2. Mother shall have primary physical custody of the children. 3. Father shall have periods of partial custody of the children. 4. Father shall have custody of Anthony every other weekend and every other major holiday. 5. Father shall have custody of Darian as the parties mutually agree, but at no point shall Darian go to Father's parents' home. 6. Mother and Father shall agree upon drop off and pick up times and locations. 7. Mother and Father shall notify each other of all medical care the children receive while in the parent's care. Mother and Father shall notify the other immediately of medical emergencies which arise while the children are in that parent's care. 8. Neither parent shall do anything which may estrange the children from the other party, or injure the opinion of the children as to the other parent or which may hamper the free and natural development of the children's love and respect for the other parent. 9. Father acknowledges that the Family Law Clinic represented only Mother's interest in this matter and has given him no legal advice other than that he should seek the advice of his own legal counsel. 10. The parties intend to be bound by the terms of this agreement and intend for this Agreement to be made an Order of Court. 11. All previous Court Orders in this matter are vacated. Stephanie Armstrong, Plaintif Paul R. Coo , Defendant J% Nicole Berman Certified Legal Intern Counsel for Plaintiff N= ?= THOMAS PLACE Counsel for Plaintiff FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717)243-2968 Fax (717)243-3639 t 4 ':-3 F7 c f">Y i`a7 N - ru +; Stephanie A. Cooper, NOW Stephanie Armstrong Plaintiff V. Paul R. Cooper, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DIVORCE : NO. 07 - 7366 CIVIL TERM CERTIFICATE OF SERVICE I, Nicole Berman, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Order of Court on Paul R. Cooper, by depositing a copy of the same in the United States mail, postage prepaid, addressed to the Defendant at 408 Centerview Avenue, New Cumberland, Pennsylvania 17070 on December 29, 2008. Nicole Berman Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 Z ?.e: 4. ?_ ??