HomeMy WebLinkAbout08-6181
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
FRANCISCO MARTINEZ NO. 08 - (o l $
Petitioner
VS. IN CUSTODY
HEATHER M. QUINN
Respondent
1. p nil L.k 1 rt 1 "
Q 'N1 FOR SHARED CUSTODY
C ivil Term
Petitioner, Francisco C. Martinez, and Respondent Heather M. Quinn, are in the process of
dissolving their domestic partnership. In an attempt to provide for the best interest of their minor
children, the parties voluntarily enter into the following agreement and in support thereof state
the following:
1. Petitioner and Respondent currently both reside at 700 Nailor Drive, Camp Hill,
Cumberland County, Pennsylvania.
2. Petitioner and Respondent agree to shared custody of the following minor children:
A. Issiah L. Quinn, minor child, age 3 was born on July 15, 2005 in Camp Hill,
Cumberland County, Pennsylvania.
B. Jayda M. Martinez, minor child, age 1 was born on October 26, 2007 in Camp
Hill, Cumberland County, Pennsylvania.
3. The children currently reside with both Petitioner and Respondent at 700 Nailor
Court, Camp Hill, Cumberland County, Pennsylvania.
4. The minor children were born out of wedlock.
5. Petitioner is the natural father of the children.
6. Respondent is the natural mother of the children.
7. Petitioner and Respondent have 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.
8. The Petitioner and Respondent have no information of a custody proceeding
concerning the children pending in a court of this Commonwealth.
9. The Petitioner and Respondent do 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.
10. The Petitioner and Respondent are both fit and proper persons to have the care,
custody and control of the minor children.
11. The Petitioner and Respondent agree to advance the welfare and the best interests of
the children and agree to demonstrate the continuing desire and ability to co-parent. Both
parties agree not to undermine the respect and affection the children have for the other parent.
12. The Petitioner and Respondent believe it is on our children's best interests to share
the physical and legal custody of our children.
13. The Petitioner and Respondent shall enjoy physical custody on a "week on - week
off' basis beginning when the parent having physical custody during the week picks the
children up from daycare on Monday no later than 5:30 p.m. and drops the children off the
following Monday no later than 8:00 a.m.
14. The Petitioner and Respondent agree that unless modification is absolutely
necessary, this agreement will remain once the children reach the age where attendance in
school becomes a factor.
15. The Petitioner and Respondent agree that since both will continue to have the same
county of residence, no special visitation set up is required for summer months. However,
each parent shall enjoy a full two weeks uninterrupted during the summer. Both parties agree
to discuss and work together on setting dates each summer.
16. The Petitioner and Respondent both have the right to make major decisions affecting
the children, including but not limited to: authorization for major medical or psychiatric care;
educational placement; and religious training. Both have the right to receive and inspect all
school and medical records. The parent having physical custody shall be responsible for
taking the children to any regularly scheduled medical or dental appointments and for
handling any medical and dental emergencies. In an emergency situation, the permissions of
both parents are unnecessary.
T
WHEREFORE, Petitioner and Respondent pray this court to:
A. Adopt the terms and conditions set forth in the attached Agreement of Shared
Custody.
Date
k
Date
Respectfully Submitted:
VERIFICATION
I verify that the statements made in this petition are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to
unsworn falsification to authorities.
Date:
Pe ' oner
VERIFICATION
I verify that the statements made in this petition are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to
unsworn falsification to authorities.
0 3 -&)?1
CERTIFICATE OF SERVICE C j v j I Te r rn
I hereby certify that on the date set forth below a true and correct copy of the foregoing
document was served upon all interested parties via US mail addressed as follows:
Francisco Martinez
700 Nailor Drive - Apt 105
Camp Hill, Pa 17011
Heather M. Quinn
700 Nailor Drive - Apt 105
Camp Hill, Pa 17011
BY:
Francisco Martinez, P ner
Date: lp - /7.O4?"
WIT
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OCT S,0200
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
FRANCISCO MARTINEZ,
Petitioner
VS.
HEATHER QUINN
Respondent
NO. D8.6I?1 C,;4 -r;',,-
IN CUSTODY
ORDER
Upon consideration of the attached Agreement of Shared Custody between Francisco Martinez,
Petitioner and Heather Quinn, Respondent, and the Court being fully informed,
IT IS HEREBY ORDERED THAT the Agreement of Shared Custody shall take effect
immediately.
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Date:
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