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HomeMy WebLinkAbout09-4231IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA : NICOLE S. GRIFFITHS, Civil Action At Law---Custody Plaintiff, Case No. O 3 ( Ca?vs. MICHAEL P. GRIFFITHS, Defendant, COMPLAINT FOR CUSTODY 1. The plaintiff is Nicole S. Griffiths, residing at 32 Regency Woods North,, Carlisle, 17013 in the County of Cumberland, Commonwealth of Pennsylvania. 2. The defendant is Michael P. Griffiths, currently residing at 111 East Locust, St. Mechanicsburg, 17055, County Cumberland, Commonwealth of Pennsylvania. 3. Plaintiff seeks custody of the following children: Name Address Aae Brooke E. Griffiths Same as Mother's dob 11/21/2001 7 years 4. Brooke E. Griffiths, was born within wedlock. 5. The child is presently in the custody of plaintiff Nicole S. Griffiths, who resides at 32 Regency Woods North, Carlisle, 17013 in the County of Cumberland, Commonwealth of Pennsylvania A 6. The child has and continues to reside with the mother at 32 Regency Woods North, Carlisle, 17013 in the County of Cumberland, Commonwealth of Pennsylvania, 7. The biological mother of the child is Nicole S. Griffiths, who currently resides at 32 Regency Woods North, Carlisle, 17013 in the County of Cumberland, Commonwealth of Pennsylvania 8. The mother is separated from the father but remains married to the same. 3. 9. The father of the child is Michael P. Griffiths, and he is currently residing at l I I East Locust, St. Mechanicsburg, 17055 Palmyra, County Cumberland, Commonwealth of Pennsylvania. 10. The father is separated from the mother but remains married to the same. 11. The relationship of the plaintiff to the child is that of a biological Mother. The Plaintiff currently resides with the following persons: Name Relationshia Brook E. Griffiths Daughter 12. The plaintiff has not participated as a party or witness, or in another capacity, in any other litigation concerning the custody of the child in this or another court. 13. The plaintiff has no other information of a custody proceeding concerning the child Pending in a Court of this Commonwealth. 14. Plaintiff 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. 15. The best interest and permanent welfare of the child will be served by Granting the relief requested because: (a) The mother can and has provided a stable, predictable and permanent environment for the children within which the children have a sense of stability and predictability with regard to their residence. (b) Plaintiff, believes and therefore avers that she can continue to provide a predictable and stable lifestyle which will be in the best interest of the children during their formative years and throughout their lives. WHEREFORE, Plaintiff, Nicole S. Griffiths, respectfully requests for the aforementioned reasons, that the court grant and award her primary physical custody of the child Brooke E. Griffiths. Dated: GREGORY S. HAZLETT (717) 790-5500 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. & 4904 relating to unsworn falsification to authorities Date: 'b' d Nicole S. Griffiths, Plat tiff C Fl LEC-!'r?1Gc OF THE 2009JI 11' 23 Pf ?: 0 3 I toy . So Po ATM CK.w? ?-?tt.V3tstoi aa?ac?9 NICOLE S. GRIFFITHS IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-4231 CIVIL ACTION LAW MICHAEL P. GRIFFITHS IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Friday, June 26, 2009 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 Tuesday, July 21, 2009 _ 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 hearinu. FOR THE COURT. By: /s/ , jacqueline M. Verney, Esq., Id 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 aF PpofH ONOTARY 2"9 JON 26 PM 3: 4 { VUlY{1.J&L" /-& vii.: t1`-.3lJtgTy ?f4S`?.Vpjg 1 asp- Q CZ` ??? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA NICOLE S. GRIFFITHS, Plaintiff, VS. Civil Action-----Custody Civil Action No. 2009-4231 MICHAEL P. GRIFFITHS, Defendant, STIPUT.ATION FOR ENTRY OF AN AGREED ORDF,R OF CUSTODY THIS STIPULATION AND AGREEMENT entered into this , day of W+e, 2009, by and between Nicole S. Griffiths, (hereinafter referred to as "Mother") and Michael P. Griffiths, (hereinafter refereed to as "Father"). NOW THIS AGREEMENT WITNESSETH THAT: WHEREAS, the Mother and Father are the natural parents of one child, by the name of Brooke E. Griffiths, (hereinafter "Child"), and WHEREAS, the parties wish to enter into an agreement relative to the custody and visitation of the child. NOW, THEREFORE, in consideration of the mutual promises, covenants and agreements as hereinafter set forth and intending to be legally bound, the parties hereto agree as follows: This agreement shall replace and supersede any other Orders or Agreements heretofore entered into by and between the parties to this agreement. 1. Mother shall have Primary Physical Custody of the child. 2. The parties shall have Shared Legal Custody of the child. 3. Father shall have Partial Physical Custody of the child, as follows: 4. The father shall have custody of the Child during the school year on Tuesday and Thursday of every week commencing at 2:30 p.m. and ending at 4:00 P.m. of the same day and the first three (3) weekends of every month to commence at 12:00 p.m. on Saturday and end on Monday whereupon father shall deliver the child to school.. 5. The father shall have custody of the child during summer vacation every Tuesday and Thursday of each week from 10:00 a.m. until 4:00 p.m. of the same day. Father shall also have the child every other weekend to commence on Saturday at 12:00 p.m. and end on Monday at 4:00 p.m. . 6. Mother shall have Primary Physical Custody of the child on all other days and times that the child is not in the custody of the father as provided to father pursuant to this agreement. 7. The child shall remain at Northside Elementary school in Mechanicsburg, PA. and in the Mechanicsburg school district beyond elementary school. Both parents shall share information relative to the childs' extracurricular activities and shall cooperate with the schedule(s) regarding the same. 8. Each parent shall have the child for two (2) non-consecutive weeks for the purpose of summer vacation. Each party shall provide the other with thirty (30) days notice of their vacation plans. 9. The parties shall share or alternate having custody of the Child on holidays as follows: A. CHRISTMAS: In every year, the Mother shall have custody of the Child from Christmas Eve at 5:00 p.m. through Christmas Day at 1:00 p.m. with the exception that father shall have Christmas eve from 6:00 p.m until 8:00 p.m. for the purpose of attending Christmas eve service whereupon father shall return the child to mothers' custody at 8:00 p.m of the same day. Father shall have custody on Christmas day at 1:00 p.m. until December 2e, at 4:00 p.m. B. THANKSGIVING* In every year, the Mother shall have custody of the Child from 9:00 a.m. until 3:00 p.m. Thanksgiving day and father shall have the child from 3:00 p.m. until 6:00 p.m. of the day after Thanksgiving. C. FASTER* In every year, the Father shall have custody of the Child until 2:00 p.m. Easter day and Mother shall have the child from 2:00 p.m. and mother shall take the child to school the following day. D. MEMORIAL DAY/1111N 4TH/I.ABOR DAY/HALLOWERN: The parties shall equally share having custody of the Child over the Memorial Day, July 4th, Labor Day and Halloween as arranged by agreement. E. MOTHER'S DAYNATHER'S DAY: In every year the Mother shall have custody of the Child on Mother's Day and the Father shall have custody on Father's Day. F. VAI,ANTINF.'S DAY In every year, the father shall have custody of the Child until 1:00 p.m. Valentine's day and mother shall have the child from 1:00 p.m. until 6:00 p.m. of the same day. G. BIRTHDAY In every year, the Father, shall have custody of the Child on the childs' birthday until 1:00 p.m. and Mother shall have the child from 1:00 p.m. until 6:00 p.m. of the same day. Each parent shall have the child on that parents' birthday. H. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 10. Unless otherwise agreed between the parties, shall meet at Wal-Mart located on the Carlisle Pike in Mechanicsburg for the purpose of all custody exchanges relative to the child. 11. Each party shall ensure that the other party has his or her current address and telephone number on an ongoing basis. 12. Neither party shall drink to the point of intoxication, while in the presence of the child during their periods of custody or allow any third party or parties to drink to the point of intoxication while the child is in their custody. 13. Neither party shall do or say anything, which may estrange the Child from the other parent. Inure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Bother parties shall ensure that third parties having contact with the child comply with this provision. 14. The parties hereto intend to be legally bound by the terms of this agreement. 15. This Agreement can only be modified, altered, or changed through the execution of a written agreement by and between the parties relative to the issue of custody. The parties by mutual agreement only, may expand or change the terms or conditions of this agreement until such time that one or both retract their consent to the change whereupon the original terms and conditions of this order shall then apply as it is written. GREGORY S. HAZLETT, ESQUIRE Gr o S. Haze , gfu 7 St Main Street echanicsburg, PA. 1705 Phone: 717-790-5500 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. r Nicole S. Griffiths COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND : s.s BE IT REMEMBERED, that on this !`l day of, ZW ` , personally appeared before me the Subscriber, a Notary Public for the State and County aforesaid, Nicole S. Griffiths, parry to this Agreement, known to me personally to be such, and she acknowledged the act of signing this Agreement. Sworn to and subscribed before me the day, month and year aforesaid Notary blic SEAL IN WITNESS WHEREOF, the parties hereto, intending to be set forth their hands and seals the day and year herein set forth. X?wl v 4 Michael P. Griffiths COMMONWEALTH OF PENNSYLVANIA : S.S. COUNTY OF CUMBERLAND BE IT REMEMBERED, that on this day of, her' wo , personally appeared before me the Subscriber, a Notary Public for the tate and County aforesaid, Michael P. Griffiths, parry to this Agreement, known to me personally to be such, and he acknowledged the act of signing this Agreement Sworn to and subscribed before me the day, month and year aforesaid Notary pya5lic NOMM SEAL (y M. IGaS ' *twy Pubk ftm b? G met M4v.19, 2010 cow? a rF THE , t ?: -? APY 2009 P !v Fi !: 4v UTV NICOLE S. GRIFFITHS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2009-4231 CIVIL ACTION - LAW MICHAEL P. GRIFFITHS, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 14th of September, 2009, having been advised that the parties have reached a stipulated agreement, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, ac line M. Verney, Esquire, Custo ?onc`liatoi` iLtu ,?. 2009 SL'I 1 a At 1; SEP 17 2009( IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA NICOLE S. GRIFFITHS, Civil Action At Law---Custody Plaintiff, Case No. 2009-4231 VS. MICHAEL P. GRIFFITHS, Defendant, ORDER OF COURT AND NOW, this, day of S `tc,b?r 2009, upon presentation of the foregoing Stipulation For Entry of an Agreed Order of Custody, executed by and between Nicole S. Griffith (hereinafter referred to as mother) and Michael P. Griffiths, (hereinafter referred to as father) relative to the custody of the child: Brooke E. Griffiths, (hereinafter referred to as child) IT IS ORDERED THAT: (a) This agreement shall replace all any and all other previous Orders issued by this or any other Court relating to the Custody of the aforementioned child. 1. Mother shall have Primary Physical Custody of the child. 2, The parties shall have Shared Legal Custody of the child. 3. Father shall have Partial Physical Custody of the child, as follows: 4. The father shall have custody of the Child during the school year on Tuesday and Thursday of every week commencing at 2:30 p.m. and ending at 4:00 P.m. of the same day and the first three (3) weekends of every month to commence at 12:00 p.m. on Saturday and end on Monday whereupon father shall deliver the child to school.. 5. The father shall have custody of the child during summer vacation every Tuesday and Thursday of each week from 10:00 a.m. until 4:00 p.m. of the same day. Father shall also have the child every other weekend to commence on Saturday at 12:00 p.m. and end on Monday at 4:00 p.m.. 6. Mother shall have Primary Physical Custody of the child on all other days and times that the child is not in the custody of the father as provided to father pursuant to this agreement. 7. The child shall remain at Northside Elementary school in Mechanicsburg, PA. and in the Mechanicsburg school district beyond elementary school. Both parents shall share information relative to the childs' extracurricular activities and shall cooperate with the schedule(s) regarding the same. 8. Each parent shall have the child for two (2) non-consecutive weeks for the purpose of summer vacation. Each party shall provide the other with thirty (30) days notice of their vacation plans. 9. The parties shall share or alternate having custody of the Child on holidays as follows: A. CHRISTMAS: In every year, the Mother shall have custody of the Child from Christmas Eve at 5:00 p.m. through Christmas Day at 1:00 p.m. with the exception that father shall have Christmas eve from 6:00 p.m until 8:00 p.m. for the purpose of attending Christmas eve service whereupon father shall return the child to mothers' custody at 8:00 p.m of the same day. Father shall have custody on Christmas day at 1:00 p.m. until December 26th, at 4:00 p.m. B. THANKSGIVING: In every year, the Mother shall have custody of the Child from 9:00 a.m. until 3:00 p.m. Thanksgiving day and father shall have the child from 3:00 p.m. until 6:00 p.m. of the day after Thanksgiving. C. EASTER: In every year, the Father shall have custody of the Child until 2:00 p.m. Easter day and Mother shall have the child from 2:00 p.m. and mother shall take the child to school the following day. D. MEMORIAL DAY/JULY 4/LABOR DAY/HALLOWEEN: The parties shall equally share having custody of the Child over the Memorial Day, July 4`h, Labor Day and Halloween as arranged by agreement. E. MOTHER'S DAY/FATHER'S DAY: In every year the Mother shall have custody of the Child on Mother's Day and the Father shall have custody on Father's Day. F. VALANTINE'S DAY In every year, the father shall have custody of the Child until 1:00 p.m. Valentine's day and mother shall have the child from 1:00 p.m. until 6:00 p.m. of the same day. G. BIRTHDAY In every year, the Father, shall have custody of the Child on the childs' birthday until 1:00 p.m. and Mother shall have the child from 1:00 p.m. until 6:00 p.m. of the same day. Each parent shall have the child on that parents' birthday. H. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 10. Unless otherwise agreed between the parties, shall meet at Wal-Mart located on the Carlisle Pike in Mechanicsburg for the purpose of all custody exchanges relative to the child. 11. Each party shall ensure that the other party has his or her current address and telephone number on an ongoing basis. 12. Neither party shall drink to the point of intoxication, while in the presence of the child during their periods of custody or allow any third party or parties to drink to the point of intoxication while the child is in their custody. 13. Neither party shall do or say anything, which may estrange the Child from the other parent. Inure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Bother parties shall ensure that third parties having contact with the child comply with this provision. 14. This agreement can be modified at any time to provide more custody to either parent but only upon the mutual consent of both parties to this agreement, in the absence of mutual agreement the terms, conditions, and restrictions of this agreement shall be adhered to in its current form, and substance for purposes of enforceability. The modification of this agreement, by mutual consent shall not be permanent nor binding unless and until a substituted written agreement is executed between the parties. 15. The modification of this agreement by mutual consent of the parties may be rescinded by either party at any time and the rescinding party can insist that the original terms, conditions and restrictions of this agreement shall be adhered to as provided for herein. BY THE COURT, FILED OF THE Pr*C, ' . ;','N' TARY 2009 SEP 17 Pt9 3: 5;3 f ?.Al'?r z td4 Q. qkmJcj { AUG ?o 6 2010 NICOLE S. GRIFFITHS, Plaintiff Vs. MICHAEL P. GRIFFITHS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA 09 - 4231 CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this 11. day of 2010, upon consideration of the joint praecipe for entry of a Custody Order, the Agreement and Stipulation dated July 30, 2010 attached hereto as Exhibit "A" is hereby incorporated as an Order of Court. kl? Gregory S. Hazlett, Esquire Attorney for Plaintiff ? Andrew C. Sheely, Esquire Attorney for Defendant & lets A m"lied 9V/3fiv 4L. BY THE COURT, s ,. r i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA ,? c -03 M - rnw M r r`'s NICOLE S. GRIFFITHS, Civil Action-----Custody X? M ca Plaintiff, n -? Q cn VS. Civil Action No. 2009-4231 c m o n ?CD © czF - r n MICHAEL P. GRIFFITHS, crt ;'1' Defendant, STIPULATION FOR ENTRY OF AN AGREED ORDER OF CUSTODY THIS STIPULATION AND AGREEMENT entered into this , day of -q-u^.#- , 2011, by and between Nicole S. Griffiths, (hereinafter referred to as "Mother") and Michael P. Griffiths, (hereinafter refereed to as "Father"). NOW THIS AGREEMENT WITNESSETH THAT: WHEREAS, the Mother and Father are the natural parents of one child, by the name of Brooke E. Griffiths, (hereinafter "Child"), and WHEREAS, the parties wish to enter into an agreement relative to the custody and visitation of the child. NOW, THEREFORE, in consideration of the mutual promises, covenants and agreements as hereinafter set forth and intending to be legally bound, the parties hereto agree as follows: This agreement shall replace and supersede any other Orders or Agreements heretofore entered into by and between the parties to this agreement. 4 1. Mother shall have Primary Physical Custody of the child. 2. The parties shall have Shared Legal Custody of the child. 3. Father shall have Partial Physical Custody of the child, as follows: 4. The father shall have custody of the Child during the school the first three (3) weekends of every month to commence on Saturday and end on Sunday whereupon the parties shall meet at the Pull Off on Rt 114 in Mechanicsburg. 5. The father shall have custody of the child during summer vacation every Wednesday and Friday of each week. Father shall also have the child every other weekend to commence on Saturday and end on Sunday at 5:00 p.m.. 6. Mother shall have Primary Physical Custody of the child on all other days and times that the child is not in the custody of the father as provided to father pursuant to this agreement. 7. The child shall be allowed to relocate to West Perry County School District. Both parents shall share information relative to the childs' extracurricular activities and shall cooperate with the schedule(s) regarding the same. 8. Each parent shall have the child for two (2) non-consecutive weeks for the purpose of summer vacation . Each party shall provide the other with thirty (30) days notice of their vacation plans. 9. The parties shall share or alternate having custody of the Child on holidays as follows: A. CHRISTMAS: In every year, the Mother shall have custody of the Child from Christmas Eve at 5:00 p.m. through Christmas Day at 1:00 p.m. with the exception that father shall have Christmas eve from 6:00 p.m until 8:00 p.m. for the purpose of attending Christmas eve service whereupon father shall return the child to mothers' custody at 8:00 p.m of the same day. Father shall have custody on Christmas day at 1:00 p.m. until December 26 th, at 4:00 p.m. B. THANKSGIVING: In every year, the Mother shall have custody of the Child from 9:00 a.m. until 3:00 p.m. Thanksgiving day and father shall have the child from 3:00 p.m. until 6:00 p.m. of the day after Thanksgiving. C. EASTER: In every year, the Father shall have custody of the Child until 2:00 p.m. Easter day and Mother shall have the child from 2:00 p.m. and mother shall take the child to school the following day. D. MEMORIAL DAY/JULY 4TH/LABOR DAY/HALLOWEEN: The parties shall equally share having custody of the Child over the Memorial Day, July 4t", Labor Day and Halloween as arranged by agreement. E. MOTHER'S DAY/FATHER'S DAY: In every year the Mother shall have custody of the Child on Mother's Day and the Father shall have custody on Father's Day. F. VALANTINE'S DAY In every year, the father shall have custody of the Child until 1:00 p.m. Valentine's day and mother shall have the child from 1:00 p.m. until 6:00 p.m. of the same day. G. BIRTHDAY In every year, the Father, shall have custody of the Child on the childs' birthday until 1:00 p.m. and Mother shall have the child from 1:00 p.m. until 6:00 p.m. of the same day. Each parent shall have the child on that parents' birthday. H. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. i 10. Unless otherwise agreed between the parties, shall meet at the Pull Off located on Route 114 in Mechanicsburg for the purpose of all custody exchanges relative to the child. 11. Each party shall ensure that the other party has his or her current address and telephone number on an ongoing basis. 12. Neither parry shall drink to the point of intoxication, while in the presence of the child during their periods of custody or allow any third party or parties to drink to the point of intoxication while the child is in their custody. 13. Neither party shall do or say anything, which may estrange the Child from the other parent. Inure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Bother parties shall ensure that third parties having contact with the child comply with this provision. 14. The parties hereto intend to be legally bound by the terms of this agreement. 15. This Agreement can only be modified, altered, or changed through the execution of a written agreement by and between the parties relative to the issue of custody. The parties by mutual agreement only, may expand or change the terms or conditions of this agreement until such time that one or both retract their consent to the change whereupon the original terms and conditions of this order shall then apply as it is written. GREGORY S. HAZLETT, ESQUIRE Phone: 717-790-5500 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. A 11- Nicole S. Griffiths COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND : s.s c?J'rday of, J f?.ll ?c , _?,??? BE IT REMEMBERED, that on this ?--- personally appeared before me the Subscriber, a Notary Public for the State and County aforesaid, Nicole S. Griffiths, party to this Agreement, known to me personally to be such, and she acknowledged the act of signing this Agreement. Sworn to and subscribed before me the day, month and year aforesaid NOTARIAL SEAL JOETTE L MCGOWEN Notary Public MECNANICSBURG BORO, CUMBERLAND CNTY My Commission Expires Jul 7, 2014 IN WITNESS WHEREOF, the parties hereto, i otary Public to be legally bound by the terms hereof, set forth th it hand seals the day and year herein set forth. Michael P. Griffiths COMMONWEALTH OF PENNSYLVANIA : S.S. COUNTY OF CUMBERLAND BE IT REMEMBERED, that on this (S day of, To n 020 , personally appeared before me the Subscriber, a Notary Public for the State and County aforesaid, Michael P. Griffiths, party to this Agreement, known to me personally to be such, and he acknowledged the act of signing this Agreement Sworn to and subscribed before me the day, month and year aforesaid N17UN& SEAL BECKY M. KN19ELY, Notary Public Mechanicsburg Som, Cumberland Co. My Commission Expires Nov 19, 2014 ,,."?.,?.?.,..... .,.?.. .....?.. ? ,U„,?.,..? ?? r IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA NICOLE S. GRIFFITHS, Civil Action At Law---Custody Plaintiff, Case No. 2009-4231 c ' -v3 rn -- r r ue rv MICHAEL P. GRIFFITHS, s " < x' C')-n Defendant, y C-- 4 ORDER OF COURT AND NOW, this th day of TO 4 t- 2011, upon presentation of the foregoing Stipulation For Entry of an Agreed Order of Custody, executed by and between Nicole S. Griffith (hereinafter referred to as mother) and Michael P. Griffiths, (hereinafter referred to as father) relative to the custody of the child: Brooke E. Griffiths, (hereinafter referred to as child) IT IS ORDERED THAT: (a) This agreement shall replace the Order of September 17", 2009 and any and all other previous Orders issued by this or any other Court relating to the Custody of the aforementioned child. 1. Mother shall have Primary Physical Custody of the child. 2. The parties shall have Shared Legal Custody of the child. 3. Father shall have Partial Physical Custody of the child, as follows: Z 4. The father shall have custody of the Child during the school the first three (3) weekends of every month to commence on Saturday and end on Sunday whereupon the parties shall meet at the Pull Off on Rt 114 in Mechanicsburg. 5. The father shall have custody of the child during summer vacation every Wednesday and Friday of each week. Father shall also have the child every other weekend to commence on Saturday and end on Sunday at 5:00 p.m. . 6. Mother shall have Primary Physical Custody of the child on all other days and times that the child is not in the custody of the father as provided to father pursuant to this agreement. 7. The child shall be allowed to relocate to West Perry County School District. Both parents shall share information relative to the childs' extracurricular activities and shall cooperate with the schedule(s) regarding the same. 8. Each parent shall have the child for two (2) non-consecutive weeks for the purpose of summer vacation. Each party shall provide the other with thirty (30) days notice of their vacation plans. 9. The parties shall share or alternate having custody of the Child on holidays as follows: A. CHRISTMAS: In every year, the Mother shall have custody of the Child from Christmas Eve at 5:00 p.m. through Christmas Day at 1:00 p.m. with the exception that father shall have Christmas eve from 6:00 p.m until 8:00 p.m. for the purpose of attending Christmas eve service whereupon father shall return the child to mothers' custody at 8:00 p.m of the same day. Father shall have custody on Christmas day at 1:00 p.m. until December 26 h, at 4:00 p.m. B. THANKSGIVING: In every year, the Mother shall have custody of the Child from 9:00 a.m. until 3:00 p.m. Thanksgiving day and father shall have the child from 3:00 p.m. until 6:00 p.m. of the day after Thanksgiving. C. EASTER: In every year, the Father shall have custody of the Child until 2:00 p.m. Easter day and Mother shall have the child from 2:00 p.m. and mother shall take the child to school the following day. D. MEMORIAL DAY/JULY 4TH/LABOR DAY/HALLOWEEN: The parties shall equally share having custody of the Child over the Memorial Day, July 40, Labor Day and Halloween as arranged by agreement. E. MOTHER'S DAY/FATHER'S DAY: In every year the Mother shall have custody of the Child on Mother's Day and the Father shall have custody on Father's Day. F. VALANTINE'S DAY In every year, the father shall have custody of the Child until 1:00 p.m. Valentine's day and mother shall have the child from 1:00 p.m. until 6:00 p.m. of the same day. G. BIRTHDAY In every year, the Father, shall have custody of the Child on the childs' birthday until 1:00 p.m. and Mother shall have the child from 1:00 p.m. until 6:00 p.m. of the same day. Each parent shall have the child on that parents' birthday. H. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 10. Unless otherwise agreed between the parties, shall meet at the Pull Off located on Route 114 in Mechanicsburg for the purpose of all custody exchanges relative to the child. 11. Each party shall ensure that the other party has his or her current address and telephone number on an ongoing basis. 12. Neither party shall drink to the point of intoxication, while in the presence of the child during their periods of custody or allow any third party or parties to drink to the point of intoxication