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HomeMy WebLinkAbout08-1531NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF ASHLEY N. MELLOTT, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW TRAVIS R. MELLOTT, : NO. 2008 - /S31 CIVIL TERM Defendant : IN CUSTODY COMPLAINT FOR CUSTODY NOW comes the Plaintiff, Ashley N. Mellott, by her attorney, Nathan C. Wolf, Esquire, and respectfully represents as follows: 1.) Plaintiff is Ashley N. Mellott, (hereinafter "Mother"), an adult individual, who resides at 131 Airport Road, Shippensburg, Cumberland County, Pennsylvania, 17257. 2.) Defendant is Travis R. Mellott, (hereinafter, "Father"), an adult individual, who resides at 7 Ian Court, Shippensburg, Cumberland County, Pennsylvania, 17257. 3.) Mother seeks an order granting shared legal custody and partial physical custody of the parties minor child, namely: Kayleigh Brooke Mellott Present Residence 131 Airport Road Shippensburg, PA 17257 Age 9 months DOB 6/14/2007 4) Mother and Father are the natural parents of the child. 5) The parties were divorced by Decree entered January 25, 2008 by the Court of Common Pleas of Potter County. 6) The child was born of the marriage of the parties. 7) The child has lived in the primary custody of mother since birth, because Father left the marital residence during the period of Mother's pregnancy on March 22, 2007. 8) Mother has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 9) Mother has no information of a custody proceeding concerning the child pending in any court of this Commonwealth or any other state. 10) Mother does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 11) The best interest and permanent welfare of the child will be served by granting the relief requested herein because Mother has been the primary caretaker of the child since the child's birth. 12.) Father has had at least some periods of custody throughout the child's life until March 1, 2008. 13) As stated above, the parties have been separated since prior to the child's birth. Since birth the child has had regular contact with Father but on March 1, 2008, Father informed Mother that he was no longer going to reside with paternal grandparents and that he would be moving into the home of his girlfriend and her parents. 14) Mother is willing to permit Father to have continued contact with the child, but because of Father's new living arrangements, the child will no longer have a bedroom to herself, and Mother object to Father having periods of overnight custody. 15) In Father's current residence, the child will either be forced to share a bedroom with a male child who is more than one year older than she, or the child will have to sleep in a crib in the room Father shares with his girlfriend. 16) Mother fears that the child will not have suitable sleeping arrangements in Father's home and thus, maybe exposed to intimate contact between Father and his girlfriend or, for the foreseeable future, the child would be sharing a room with a male child to whom she is not related. 17.) Father has consistently allowed his caretaking responsibilities to be borne by his parents and Father has not been significantly involved in the care of the child. 18) Therefore, until Father can ensure that he has suitable sleeping arrangements for the child and until Father can demonstrate that he is able to care for the child if left in his primary care, Mother seeks an Order limiting Father's periods of partial physical custody to exclude overnight stays with Father. 19) Mother will soon be moving back to Cumberland County to reside with her parents while she establishes sufficient financial ability to purchase her own home. 20) Mother believes and therefore avers that without an Order granting the relief requested herein, Father may refuse to return the child to Mother's custody. 21) Mother submits that if granted the relief request, she will continue to encourage and reinforce the relationship between the child and Father. 22) Mother submits that an Order granting the relief requested would promote the best interests and permanent welfare of the child. WHEREFORE, for the reasons set forth herein, Plaintiff, Ashley N. Mellott, respectfully requests that the Court enter an order confirming shared legal custody and establishing a schedule for primary physical custody of the child to the Plaintiff, and a schedule for partial physical custody to the Defendant without overnight periods along with granting any other relief the Court deems appropriate and just. Respectfully submitted, WOLF & 1WOI.F , March -Z, 2008 NA C. WOLF, ESQUIRE Att rn for Plaintiff 10 est High Street Carlisle, Pennsylvania 17013-2922 (717) 241-4436 Supreme Court I.D. No. 87380 VERIFICATION I do hereby verify that I am the plaintiff in the foregoing action and that the facts set forth in this complaint are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unworn falsification to authorities. March (D, 2008 Ashley llott NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-0436 ATTORNEY FOR PLAINTIFF ASHLEY N. MELLOTT, Plaintiff V. : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW TRAVIS R. MELLOTT, : NO. 2008 - CIVIL TERM Defendant : IN CUSTODY CERTIFICATE OF SERVICE I, the undersigned, hereby certify that on the date indicated below, I caused the foregoing Complaint for Custody to be served upon the defendant, by mailing the same via Fast Class Mail, addressed as follows: Travis R. Mellott 7 Ian Court Shippensburg, PA 17257 WOLF & WOLF Dated: March 1, 2008 By: Nath C olf, Esquire Co for Plaintiff IL .11) C J ? f ? C= i Fr ?' t i Q s-,. C>23 a Cil ASHLEY N. MELLOTT PLAINTIFF V. TRAVIS R. MELLOTT . IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA 2008-1531 CIVIL ACTION LAW . IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Thursday, March 13, 2008 , 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, April 24, 2008 at 8:30 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: /s/ Hubert X. Gilroy, Es q. 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 7JW -;2 111 .Z 1.1d C I M 6001 11.11;:1 3HI K) r13?1J t MAY @1 Z009r ASHLEY N. MELLOTT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW TRAVIS R. MELLOTT, : NO. 2008-1531 Defendant : IN CUSTODY COURT ORDER +h AND NOW, this ? day of _R"_ , 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Ashley N. Mellott, and the Father, Travis R. Mellott, shall enjoy shared legal custody of Kayleigh Brooke Mellott, born June 14, 2007. 2. The Mother shall have primary physical custody of the minor child. 3. Father shall have periods of temporary physical custody of the minor child as follows: A. On alternating weekends from Saturday at 5:00 a.m. or when Father gets off work until Monday morning when Father may return the child to the babysitter; B. On every Tuesday and Thursday from 3:00 p.m. until 7:00 p.m. Starting July 1, 2008, the Tuesdays and Thursdays shall be overnight with the Father picking up the child at 3:00 p.m. and returning the child to the babysitter the next day. C. At such other times as the parties agree. 4. Father shall reasonably attempt to create some type of partition in the bedroom where he resides so that the minor child shall have some sort of separation from the other child who is sleeping in the same bedroom. Additionally, subject to Father's financial situation, Father shall attempt at the end of his current lease to obtain a three bedroom apartment that would allow the minor child to have a separate bedroom. 5. This Order is entered pursuant to an agreement reached by the parties at a Custody Conciliation conference. In the event either party desires to modify this Order, that party may petition the Court to have the case again scheduled with the Custody Conciliator for a conference. BY THE COURT, Judge cc: '? athan C. Wolf, Esquire ?Ga1'e"r J Mr. Travis Mellott 1 dINVAIASNN3d 6? :8 WV 9- AVW0001 AbVIONGHIOdd 4 JO Ku--Ct-! r ASHLEY N. MELLOTT, Plaintiff v TRAVIS R. MELLOTT, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008-1531 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Kayleigh Brooke Mellott, born June 14, 2007 2. A Conciliation Conference was held on April 24, 2008, with the following individuals in attendance: The mother, Ashley N. Mellott, with her counsel, Nathan C. Wolf, Esquire The father, Travis R. Mellott, who appeared without an attorney. 3. The parties agreed to an entry of an Order in the form as attached. Date: April , 2008 4` '/ I 1\\Yj/J Hubert X. Gil?*y, Esquire Custody Co ciliator Travis R. Mellott : In the Court Of Common Pleas Of Plaintiff : Cumberland County, Pennsylvania V : Civil Action -Law Ashley N. Mellott : No. 2008 -1531 Defendant : In Custody Petition to Modify Custody NOW, Monday the 270' of October, I am Filing my Petition to Modify Custody. I want to go from my current custody agreement to a set 50/50 agreement. Stating either a 2-2-3 cycle or every other week, I want to sit and have it all in black and white including holidays, pick up and drop of accommodations. Since there will be a set 50150 custody agreement I want to also be able to claim child every other year at income tax time. An alterative babysitting arrangement needs to be discussed as well, current babysitter is working two jobs one is the graveyard shift and then she gets child in the mornings and travels after being up all night were she does her second job which is taking care of an elderly lady in her home. With baby sitter working two jobs it also throws off my days to have the child because the babysitter don't get off the graveyard shift until 6:30 am and I have to be at work by 6 am. I don't feel that its right for the babysitters schedule to be able to determine the time I spend with my child. At the previous conciliation I had agreed that at the end of my lease in March of 2009 I would attempt to look for a three bedroom establishment. I want mother to attempt to make better accommodations for the child as well its only fair instead of living in her parents' cold and damp basement when the child has allergies and her nose is constantly running. Finally if mother needs to leave town or travel out of state for any reason I want her to call as much in advance as she can to make arrangements not just call and say hey I'm off for North Carolina in the morning and I'm taking your daughter with me, especially when it's on my time to have her. She doesn't run her life alone I need to be included more and there needs to be better and less selfish communication. Travis R. Mellott MAY 0 1 2008?? P ASHLEY N. MELLOTT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW TRAVIS R. MELLOTT, : NO. 2008-1531 Defendant : IN CUSTODY COURT ORDER AND NOW, this 1.4- day of , 2008, upon consideration of the attached Custody Conciliation Report, it is orde Jed and directed as follows: 1. The Mother, Ashley N. Mellott, and the Father, Travis R. Mellott, shall enjoy shared legal custody of Kayleigh Brooke Mellott, born June 14, 2007. 2. The Mother shall have primary physical custody of the minor child. 3. Father shall have periods of temporary physical custody of the minor child as follows: A. On alternating weekends from Saturday at 5:00 a.m. or when Father gets off work until Monday morning when Father may return the child to the babysitter; B. On every Tuesday and Thursday from 3:00 p.m. until 7:00 p.m. Starting July 1, 2008, the Tuesdays and Thursdays shall be overnight with the Father picking up the child at 3:00 p.m. and returning the child to the babysitter the next day. C. At such other times as the parties agree. 4. Father shall reasonably attempt to create some type of partition in the bedroom where he resides so that the minor child shall have some sort of separation from the other child who is sleeping in the same bedroom. Additionally, subject to Father's financial situation, Father shall attempt at the end of his current lease to obtain a three bedroom apartment that would allow the minor child to have a separate bedroom. 5. This Order is entered pursuant to an agreement reached by the parties at a Custody Conciliation conference. In the event either party desires to modify this Order, that party may petition the Court to have the case again scheduled with the Custody Conciliator for a conference. BY THE COURT, ;. , . - dge cc: Nathan C. Wolf, Esquire Jl, i 1161 U. Mr. Travis Mellott 0 - w ASHLEY N. MELLOTT, Plaintiff v TRAVIS R. MELLOTT, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008-1531 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Kayleigh Brooke Mellott, born June 14, 2007 2. A Conciliation Conference was held on April 24, 2008, with the following individuals in attendance: - The mother, Ashley N. Mellott, with her counsel, Nathan C. Wolf, Esquire The father, Travis R; Mellott, who appeared without an attorney. 3. The parties agreed to an entry of an Order in the form as attached. Date: April, 2008 Hubert X. Gili;6y, Esquire Custody Cop4liator SsV TRAVIS R. MELLOTT IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. ASHLEY N. MELLOTT DEFENDANT 2008-1531 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, October 30, 2008 , 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 Friday, December 05, 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: /s/ Hubert X. Gilroy, 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 ? .4 Wd 0c 130 OCR 3HI , Pi- w DEC 17 20M (,7 TRAVIS R. MELLOTT, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW ASHLEY N. MELLOTT, NO. 2008-1531 Defendant IN CUSTODY COURT ORDER AND NOW, this Nay of December, 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: A hearing is scheduled in Court Room No. 5 of the Cumberland County Courthouse on the day of /13R 1, 2009 at LQ_#.m. At this hearing, the father shall be the moving party and shall proceed initially with testimony. Counsel for the parties, or the parties themselves if they do not have counsel, shall file with the Court and opposing counsel/party a memorandum setting forth the history of custody in this case, the issues currently before the Court, a summary of each parties position on these issues, a list of witnesses who will be called to testify on behalf of each party and a summary of the anticipated testimony of each witness. This memorandum shall be filed at least five days prior to the mentioned hearing date. 2. Pending further Order of this Court, this Court's Order of May 6, 2008, shall remain in place and the parties shall continue to work the holiday schedule the way they have agreed in past and pursuant to the agreement discussed at the Custody Conciliation Conference. BY THE COURT, Judge M.L. Ebert, Jr. cc: /XT athan C. Wolf, Esquire / Mr. Travis R. Mellott loo "-?9 5 ;r t ?°+if irk J, N ? I :Z k'8 81 33,0 9001 3Ai 30 fir`'!,?_'•` w -????1-3 .m TRAVIS R. MELLOTT, Plaintiff v ASHLEY N. MELLOTT, Defendant PRIOR JUDGE: M.L. Ebert, Jr. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008-1531 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Kayleigh Brooke Mellott, born June 14, 2007. 2. A Conciliation Conference was held on December 16, 2008, with the following individuals in attendance: The mother, Ashley N. Mellott, with her counsel, Nathan C. Wolf, Esquire, and the father, Travis R. Mellott, who appeared without counsel. 3. Father is petitioning to have the existing Order modified and is seeking a 50150 custodial arrangement. The existing Order was entered upon agreement of the parties in May of 2008 after a conciliation conference. However, father suggests that he agreed at that time to mother having primary custody simply because he had not seen the child overnight for a period of time and this was an Order to get things put back into place with father having overnight visitation. Father now believes there is no reason why it should not be a 50150 situation. Mother suggests the existing situation is satisfactory and is not willing to accommodate father's request. 4. A hearing is required in this case and the Conciliator recommends an Order in the form as attached. Date: 611468 Hubert X. Gilroy, Es wire Custody Conciliat NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF ASHLEY N. MELLOTT, Plaintiff V. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW TRAVIS R. MELLOTT, : NO.2008-1531 CIVIL TERM Defendant : IN CUSTODY STIPUIA7"rnrr,a A RFFMF THIS STIPULATION AND AGREEMENT entered into this -L9 day of ?r 2009, by and between TRAVIS R. MELLOTT (hereinafter referred to as "Father") and ASHLEY N. MELLOTT (hereinafter referred to as "Mother"). NOW THIS AGREEMENT WITNESSETH THAT: WHEREAS, the Father and Mother are the parents of one minor child, namely, KAYLEIGH BROOKE MELLOTI'(age 20 Months, born June 14,2007); and, WHEREAS, the parties are subject to a custody order entered at this term and docket on May 6, 2008, by the Honorable M.L. Ebert, Jr., and now wish to enter into an amended agreement relative to the custody of the parties' child; and, NOW, THEREFORE, in consideration of the mutual covenants, promises and agreements as hereinafter set forth and intending to be legally bound, the parties hereto agree as follows: 1. The parties shall have shared legal custody of the child. 2. The parties shall have shared physical custody of the child to be alternated in accordance with the following two-week schedule beginning Monday, March 2, 2009: a. During week one, Mother shall have custody from 5:30 a.m. Monday until 5:30 a.m. Wednesday morning; b. Father shall then have custody from Wednesday at 5:30 a.m. until Friday at 5:30 a.m.; c. Mother shall then have custody from Friday at 5:30 a.m. until the following Monday at 5:30 a.m.; d. During week two, Father shall have custody from 5:30 a.m. Monday until 5:30 a.m. Wednesday morning; e. Mother shall then have custody from Wednesday at 5:30 a.m. until Friday at 5.30 a.m.; and f. Father shall then have custody from Friday at 5:30 a.m. until the following Monday at 5:30 a.m. 3. At the end of each parent's overnight period, the child shall be dropped off at the home of paternal grandparents for daytime childcare, unless alternate childcare arrangements have been made, to which both parties agree. Nothing in this provision shall prohibit the parent from retaining custody during work hours, if that parent is not scheduled to work 4. The parties shall share custody of the child on holidays as follows, which schedule is designed to correspond with Mother's work schedule: a. For each holiday referenced herein, the parent receiving custody at 3:00 p.m. on the day of the holiday shall have custody until the following morning at 5:30 a.m., when the normal schedule of custody shall resume. b. In 2009 and odd years thereafter, Mother shall have custody of the child on the Thanksgiving holiday from 7:30 p.m. on the evening before, until 3:00 p.m. of Thanksgiving day, and Father shall have custody of the child for the same time period in even numbered years. c. In 2009 and odd years thereafter, Father shall have custody of the child from 7:30 p.m. on Christmas Eve, until 3:00 p.m. on Christmas Day and Mother shall have custody of the child for the same time period in even numbered years. d. In 2009 and odd years thereafter, Mother shall have custody of the child on the Easter holiday from 7:30 p.m. on the evening before, until 3:00 p.m. of Easter Sunday, and Father shall have custody of the child for the same time period in even numbered years. e. In odd-numbered years beginning with New Year's Day 2009, Father shall have custody of the child on New Year's Eve beginning at 7:30 p.m., until 3:00 p.m. New Year's Day, and Independence Day from 7:30 p.m. on July 3`d, until 3:00 p.m. on July 4`t', and Mother shall have custody of the child from 7:30 p.m. on the Sunday before Memorial Day and Labor Day until 3:00 p.m. on the each of those respective holidays. This schedule shall alternate in even numbered years, beginning with Mother having custody on the New Year's holiday in 2010. f. Each party shall be entitled to a total of one week of uninterrupted vacation with the child during the summer vacation period. The party seeking to exercise said week of vacation shall notify the other party in writing no less than thirty (30) days prior to the date the week would commence. 5. Transportation of the child shall be shared such that the parties shall meet to exchange custody at a mutually agreed upon location. 6. The parties shall keep each other advised immediately relative to any emergencies concerning the child and shall further take any necessary steps to insure that the health, welfare and well being of the child are protected. 7. The parties shall do nothing that may estrange the child from either party or hinder the natural development of the child's love or affection for the other party. Any modification or waiver of any of the provisions of this agreement shall be effective only if made in writing. 9. The parties agree that in making this agreement there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other. 10. In the event of the breach of the agreement of the parties by any party, the nonbreaching party shall have the right to file a petition for contempt of court and to seek specific performance of the terms of the agreement of the parties. 11. The parties desire that this agreement be made an order of Court through the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberland County has jurisdiction over the issue of custody of the parties' minor child. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound by the terms hereof, set forth their hands and seals the day and year herein set forth. (SEAL) TRA S . MELLOTT (SEAL) ASHLEY ELLOTT COMMONWEALTH OF PENNSYLVANIA : :SS: COUNTY OF CUMBERLAND On this, the (Ci" day of , 2009, before, the undersigned officer, appeared TRAVIS R. MELLOTT known to me (ors tisfactorilyproven) to be the same person whose name is subscribed to the within instrument, and acknowledged that he executed this agreement for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL [am, ICHELE R OliF . }: w+,tary Public ro of Shippeasburg, cu+nberland County Nota Public y Commis&on Expires July 16, 2012 rY COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND :SS: On this, the dayof ue",?el , 2009, before, the undersigned officer, appeared ASHLEY N. MELLOTT, known to me ( r satisfactorily proven) to be the same person whose name is subscribed to the within instnument, and acknowledged that she executed this agreement for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set myh? d official seal. COMMONWEALTH OF PENNSYLVANIA 4ub (S EAL) Notarial Seal Naman C Wolf, Notary Public y Carlisle Boro, Cumberiand County My Commission Expires April 19, 2012 Member, Pennsylvania Association of Notaries ?? ? ? _;-, ? ? -..- ? z t,'; ,,,3 _ -+ ,,,:c. ?? ?'Sl ? ? ?. ? ? MAR 2000 ? ASHLEY N. MELLOTT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW TRAVIS R. MELLOTT, : NO.2008-1531 CIVIL TERM Defendant : IN CUSTODY ORDER OF COURT NOW, this 1I _ day of h ai 3^ , 2009, upon presentation and consideration of the attached Stipulation and Agreement and upon agreement of the parties, it is hereby ordered and decreed that the attached agreement is made an Order of Court. BY THE COURT, `?.t CQJ,? -' Distribution: Nathan C. Wolf, Esquire For the Plaintiff Travis R. Mellott Pro Se Defendant n ? , 11?? t?v\