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HomeMy WebLinkAbout04-1269IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEBORAH L. GORDON, : Plaintiff : : CIVIL ACTION - LAW : NUMBER: THEODORE P. GORDON III, : Defendant : IN CUSTODY MOTION NOW COMES the Plaintiff, DEBORAH L. GORDON, by and through her attorney, Charles E. Petrie, and respectfully represents as follows: 1. That Plaintiff is DEBORAH L. GORDON, an adult individual currently residing at 181 Creek Road, Newville, County of Cumberland, Pennsylvania. 2. That Defendant is THEODORE P. GORDON III, an adult individual currently residing at an address in the County of Cumberland, Pennsylvania. 3. That Plaintiff and Defendant are the natural parents of two minor children, DEVON N. GORDON, born October 1, 1995; and LeANN M. GORDON, born March 19, 1999. 4. That the parties have entered into a Stipulation concerning the matters of custody and visitation with respect to the minor children, and the said Stipulation is attached hereto. DEBORAH L. GORDON, Plaintiff VS. THEODORE P. GORDON III, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NUMBER: : : IN CUSTODY STIPULATION AGREEMENT, made this ~F~day of ]~f')~CC['~ ,2004, byand between THEODORE P. GORDON III, hereinafter referred to as "Father;" and DEBORAH L. GORDON, hereinafter referred to as "Mother;" WITNESSETH: WHEREAS, the parties hereto are the natural parents of two minor children, DEVON N. GORDON, born October 1, 1995; and LeANN M. GORDON, born March 19, 1999; and WHEREAS, the parties have reached an agreement concerning the issues of custody and desire that this Stipulation be entered as Order by the Court of Common Pleas of Cumberland County, Pennsylvania; NOW, THEREFORE, intending to be legally bound, the parties hereby agree as follows: 1. It is the intention of the parties and the parties agree that they will share joint legal custody of their minor children, DEVON N. GORDON, born October 1, 1995; and LeANN M. GORDON, born March 19, 1999. The parties agree that major decisions concerning the children, including, but not necessarily limited to, the children's health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in the children's best interests. Each party agrees not to impair the other party's right to shared legal custody of the children. Each party agrees not to attempt to alienate the affections of the children from the other party nor to permit any third person to attempt to so alienate the affections of the children from the other party. Each party shall notify the other of any activity or circumstance concerning the children that could reasonably be expected to be of concern to the other. Day-to-day decisions shall be the responsibility of the party then having physical custody. With regard to any emergency decisions which must be made, the party having physical custody of the children at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that party shall inform the other of the emergency and consult with him or her as soon as possible. Each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports given to either party. 2. Mother, DEBORAH L. GORDON, shall have primary physical custody of the subject minor children. 3. Father, THEODORE P. GORDON III, shall have temporary physical custody of the minor children as the parties shall agree which shall not be less than one overnight visit per week. IN WITNESS WHEREOF, the parties have hereunto set their hands and :ea:.~day and year first above written. WITNESS WITNESS THEODORE P. GORDON III DEBORAH L. GORDON DEBORAH L. GORDON, Plaintiff VS. THEODORE P. GORDON III, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NUMBER: (~)~-//),/~q bet : IN CUSTODY ORDER AND NOW, this K"day of ~p~? , 2004, upon ,consideration of the within Motion, Stipulation, and Complaint, it is hereby Ordered as follows: 1. It is the intention of the parties and the parties agree that they will share joint legal custody of their minor children, DEVON N. GORDON, born October 1, 1995; and LeANN M. GORDON, born March 19, 1999. The parties agree that major decisions concerning the children,, including, but not necessarily limited to, the children's health, welfare'., education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in the children's best interests. Each party agrees not to impair the other party's right to shared legal custody of the children. Each party agrees not to attempt to alienate the affections of the children from the other party nor to permit any third person to attempt to so alienate the affections of the children from the other party. Each party shall notify the other of any activity or circumstance concerning the children that could reasonably be expected to be of concern to the other. Day-to-day decisions shall be the responsibility of the party then having physical custody. With regard to any emergency decisions which must be made, the party having physical custody of the children at the time of the emergency shall be permitted to make any immediate decisions necessitated there]~)Y· However, that party shall inform the other of the emergency and consult with him or her as soon as possible. Each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports given to either party. 2. Mother, DEBORAH L. GORDON, shall have primary physical custody of the subject minor children. 3. Father, THEODORE P. GORDON III, shall have temporary physical custody of the minor children as the parties shall agree which shall not be less than one overnight visit per week. BY THE COURT: