HomeMy WebLinkAbout01-7033Edgar Freed/12.13.01. Custody Order
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
EDGAR A. FREED, JR,
Plaintiff
V.
KELLY M. FREED,
Defendant
NO.~- 7d~CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
CUSTODY ORDER
AND NOW, this / ~" day of December, 2001, upon consideration of
the within Custody Agreement dated September 26, 1995, Kelly M.
Freed (~Mother") and Edgar A. Freed, Jr. (~Father") pertaining to
their minor children: Erica C. Freed, born September 28, 1984 and
Kelsey A. Freed, born January 11, 1988 (~the Children), IT IS
HEREBY ORDERED A/gD DECREED that the terms of the within Stipulation
are incorporated by reference hereto and are hereby entered as an
Order of Court.
Distribution to:
BY THE COURT:
/
I DIANE G. P3~DCLIFF, ESQUIRE
3448 TRINDLE ROAD,
CAMP HILL, PA 17011
ATTORNEY FOR EDGAR A. FREED, JR.
IEDGAR A. FREED, JR.
105 E. COLUMBIA DR.
ENOLA, PA 17025
KELLY M. FREED
PERRY MANOR
111 FROG HOLLOW RD
NEWPORT, PA 17074
PRO SE
Edgar Freed/12.13.01. Custody Order
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
EDGAR A. FREED, JR,
Plaintiff
KELLY M. FREED,
Defendant
NO.~-~O~CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
~ NOW, this 14th day of December, 2001, Diane G. Radcliff,
Esquire, Attorney for Edgar A. Freed, Jr., Plaintiff, hereby moves
this Honorable Court to enter the terms of the parties' Custody
Agreement dated September, 25, 1999 as an order of court, the entry
of said order being authorized by the terms of that agreement.
Respectfully submitted,
D~--ANE G. RADC~FF~---ESQ~IRE
3 ~'~indl e Ro~d
C~!~ Hill, PA...i/7011
Phone: (717) 737-0100
Fax: (717) 975-0695
Supreme Court ID # 32112
Attorney for Plaintiff
//
CERTIFICATE OF SERVICE
AND NOW this I ~'-~day of~C 0=._~2001, I, DIANE G.
P~ADCLIFF, ESQUIRE, hereby certify that I have this day served a
copy of the foregoing document upon the following named person, by
mailing same by first class mail, postage prepaid, addressed as
follows:
Kelly M. Freed
Perry Manor
111 Frog Hollow Road
Newport, PA 17074
Edgar A. Freed
105 E. Columbia Dr.
Enola, PA 17025
Respectfully submitted,
Phone: (717) 737-0100
Fax: (717) 975-0697
Supreme Court ID # 32112
- 3 -
DIANE G. RADCLIFF
ATTORNEY-AT-LAW
3448 TRINDLE ROAD
CAMp HILL, PA 170Il
CUSTODY AGREEMENT
made this-..,~J)~ay of~ 1995, by and
THIS
AGREEMENT
between EDGAR A. FREED, JR. of Enola, Pennsylvania (hereafter referred to as
"Father") and KELLY M. FREED of Newport, Pennsylvania (hereafter referred to
as "Mother'), the parties agrcc as follows with respect to ERICA C. FREED, born
September 28, 1984; KELSEY A. FREED born January 11, 1988; and TIFFANY
A. POPP born March 13, 1982, (hereafter referred to as "Children"):
1. PHYSICAL CUSTODY:
(a) Father shall have primary physical custody of the Children and
Mother shall have partial physical custody of the Children at such times as
the parties shall mutually agree.
(b) Absent such mutual agreement, the following schedule of
partial custody of Erica C. Freed and Kelsey A. Freed with Mother shall
apply:
(1) Alternating wcckends commencing on Friday at 6:00
p.m. until Sunday at 6:00 p.m.
(2) From 9:00 a.m. until 6:00 p.m. on alternating major
holidays including Easter Day, Memorial Day, Independence Day,
DIANE G. RADCLIFF
ATTORNEY-AT-LAW
3448 TRINDLE ROAD
CAMP HILL, PA 1701!
Labor Day, Thanksgiving Day, Christmas Eve Day and Christmas
Day.
(3) Two non-consecutive weeks of vacation time for each
party upon thirty (30) days advance notice to the other party.
(c) Absent mutual agrccment, Mother shall have partial custody
of Tiffany A. Popp at such times as Tiffany shall desire.
2. MISCELLANEOUS:
(a) The aforementioned holiday schedule shall take precedence
over any other custodial period and shall not be interrupted thereby.
(b) The aforementioned two week vacation periods shall take
precedence over any other custodial period excepting holidays and shall
not be interrupted thereby.
(c) Upon mutual agreement the parties may expand or alter these
custodial arrangements as may be in the best interest of the Children.
(d) Each party shall have reasonable telephone access with the
Children and the Children shall be pecmitted free access to place or receive
telephone calls to or from either parent if they desires.
(e) If either parent desires to relocate and establish a residence
more than 100 miles from their current residence, he or she shall give the
other party at least 60 days advance written notice of his or her proposed
DIANE G. RADCLIFF
ATTORNEY-AT-LAW
3448 TRINDLE ROAD
CAMP HILL, PA 1701!
relocation, in order to give the parties an opportunity to confer pdor to such
relocation and to establish a mutually satisfactory arrangement as to
custody and partial custody in light of such relocation. In the event the
parties am unable to reach a mutually agreeable arrangement, then either
party shall have the right to petition a court of competent jurisdiction to
enter an appropriate custody/partial custody order.
(f) This Stipulation may be entered as an order of court in any
court of competent jurisdiction at the request of either party.
IN WITNESS WHEREOF, the parties, intending to be legally bound hereby,
have hereunto set their hands and seals thisc~day of
1995.
WITNESS:
A. FREED, JR.
(SEAL)
KELLY M. ~:REED