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HomeMy WebLinkAbout01-7180 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Colleen R. Craig, : Civil Action - Law Plaintiff : : v. :No. Stewart P. Craig, : Defendant : In Custody STIPULATION 1. Plaintiff(hereinafter"Mother") is Colleen Craig, an adult individual currently residing at 11 Thompson Creek Drive, Shippensburg, Cumberland County, Pennsylvania 17257. 2. Defendant (hereinafter "Father") is Stewart P. Craig, an adult individual residing at 85 Old Sawmill Lane, Newburg, Cumberland County, Pennsylvania 17240. 3. Plaintiff is the natural mother of the child, Rayna Craig, bom May 16, 1996. The Defendant is the natural father of the child. The child was bom out of wedlock. 4. The relationship of the Plaintiffto the child is that of natural mother. The Plaintiffcurrently resides with the minor child and her parents, Jack and Evelyn Dale. 5. The relationship ofthe Defendant to the child is that of natural father. The Defendant currently resides alone. 6. Since birth, the child has resided at the following addresses with the following persons: a. From birth until August 2000, the child resided at 16 Town Mills, Shippensburg, Pennsylvania with her mother and father. b. From August 2000 until August 6, 2001, the child resided at 85 Old Sawmill Lane, Newburg, Cumberland County, Pennsylvania with mother and father. c. From August 6, 2001 until the present, the child has resided at 11 Thompson Creek Drive, Shippensburg, Cumberland County, Pennsylvania with her mother and maternal grandparents. 7. Mother has not participated as a party in other litigation conceming the custody o fthe child in another court. Mother has no knowledge ofany other custody proceedings concerning the child pending in any court of this Commonwealth. Mother does not know of any other people not a party to these proceedings who have physical custody of the child or claim to have custody or visitation rights withrespect to the child. 8. BothMother and Father agree that it is in the best interest of the child for the Court to enter the attached Order of Court as an Order. 9. Mother has been represented by Carrie M. Bowmaster, Esquire. Father has been given the opportunity to seek counsel, but has decided to proceedpro se. WHEREFORE, this /s~Udayof 0c~/0~,e(2001, Mother and Father, intending to be legally bound and waiving their right to be present when this agreement and order are presented and executed, hereby stipulate and agree that the Court may enter the following order in the above captioned case: ORDER OF COURT AND NOW, this __ day of . ,2001, based on the stipulation of the parties, the Court hereby Orders as follows: 1. Plaintiff(hereinafter"Mothef) and Defendant (hereinafter"Fathef)shallhave shared legal custody of their minor child, Rayna Craig, bom May 16, 1996. 2. Mother shall have primary residential custody of the child. 3. Father shall have partial custody as follows: a. On alternating weekends from Friday at 5:00 p.m. until Sunday at 7:00 p.m.; b. Two evenings each week as the parties maymutually agree. During the school year, she shall be returned to Mother's home by 8:00 p.m. During the summers, she shall be able to stay overnight with Father or be turned by 10:00 p.m. Exact arrangements shall be agreed upon by the parties. c. At other times mutually agreeable to the parties. 4. Summers. Each parent shall be entitled to have periods of uninterrupted custody as they may mutually agree. 5. Holidays. Holidays shall be divided as the parties shall mutually agree. 6. Transportation. The parties shall agree to the transportation necessary for Father's periods of custody. 7. Mother shall claim the child on her income tax returns. 8. The parties consent to the 39th Judicial District - Franklin County Branch having jurisdiction over this matter. 9. Plaintiff has paid the filing costs for this matter. By the Court, The parties further agree that in the procuring of this agreement there has been no fzaud, concealment, overreaching, coercion or other unfair dealing by either party. IN WITNESS WHEREOF, the parties, intending to be legally bound, have signed hereunto. WITNESS Stewart Craig I verify that the statements made in the foregoing Stipulation are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Date: ]~./t ,/ I verify that the statements made in the foregoing Stipulation are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Date: to. !- ~/ Stewart Craig O(ySg-Z9L'L I L 900~,'L9Z'LIL ~aS u~pl '~ Colleen R. Craig, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Civil Action - Law v. :No. Stewart P. Craig, : Defendant : In Custody h STI?ULATION 1. Plaintiff(hereinafter"Mother") is Colleen Craig, an adult individual currentlyresiding at 11 Thompson Creek Drive, Shippensburg, Cumberland County, Pennsylvania 17257. 2. Defendant (hereinafter "Father") is Stewart P. Craig, an adult individual residing at 85 Old Sawmill Lane, Newburg, Cumberland County, Pennsylvania 17240. 3. Plaintiff is the natural mother of the child, Rayna Craig, born May 16, 1996. The Defendant is the natural father of the child. The child was bom out of wedlock. 4. The relationship of the Plaintiffto the child is that of natural mother. The Plaintiffcurrently resides with the minor child and her parents, Jack and Evelyn Dale. 5. The relationship ofthe Defendant to the child is that of natural father. The Defendant currently resides alone. 6. Since birth, the child has resided at the following addresses with the following persons: a. From birth until August 2000, the child resided at 16 Town Mills, Shippensburg, Pennsylvania with her mother and father. b. From August 2000 until August 6, 2001, the child resided at 85 Old Sawmill Lane, Newburg, Cumberland County, Pennsylvania with mother and father. c. From August 6, 2001 until the present, the child has resided at 11 Thompson Creek Drive, Shippensburg, Cumberland County, Pennsylvania with her mother and maternal grandparents. 7. Mother has not participated as a party in other litigation concerning the custody of the child in another court. Mother has no knowledge ofany other custody proceedings concerning the child pending in any court of this Commonwealth. Mother does not know of any other people not a party to these proceedings who have physical custody o fthe child or claim to have custody or visitation rights with respect to the child. 8. Both Mother and Father agree that it is in the best interest of the child for the Court to enter the attached Order of Court as an Order. 9. Mother has been represented by Carrie M. Bowmaster, Esquire. Father has been given the opportunity to seek counsel, but has decided to proceedpro se. WHEREFORE, this ]~t~day of /9c/0~e~2001, Mother and Father, intending to be legally bound and waiving their right to be present when this agreement and order are presented and executed, hereby stipulate and agree that the Court may enter the following order in the above captioned case: ORDER OF COURT AND NOW, this day of ,2001, based on the stipulation of the parties, the Court hereby Orders as follows: 1. Plaintiff(hereinafier'Wlother") andDefendant (hereinafier"Fathef') shallhave shared legal custody of their minor child, Rayna Craig, bom May 16, 1996. 2. Mother shall have primary residential custody of the child. 3. Father shall have partial custody as follows: a. On alternating weekends from Friday at 5:00 p.m. until Sunday at 7:00 p.m.; b. Two evenings each week as the parties may mutually agree. During the school year, she shall be returned to Mother's home by 8:00 p.m. During the summers, she shall be able to stayovemight with Father or be turned by 10:00 p.m. Exact arrangements shall be agreed upon by the parties. c. At other times mutually agreeable to the parties. 4. Summers. Each parent shall be entitled to have periods of uninterrupted custody as they may mutually agree. 5. Holidays. Holidays shall be divided as the parties shall mutually agree. 6. Transportation. The parties shall agree to the transportation necessary for Father's periods of custody. 7. Mother shall claim the child on her income tax returns. 8. The parties consent to the 39th Judicial District - Franklin County Branch having jurisdiction over this matter. 9. Plaintiff has paid the filing costs for this matter. By the Court, The parties further agree that in the procuring of this agreement there has been no fraud, concealment, overreaching, coercion or other unfair dealing by either party. IN WITNESS WHEREOF, the parties, intending to be legally bound, have signed hereunto. W1TNESS ~flleen r~ig/~ Stewart Craig I verify that the statements made in the foregoing Stipulation are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Date: I verify that the statements made in the foregoing Stipulation are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Date: Stewart Craig Colleen R. Craig, Plaintiff Stewart P. Craig, Defendm~t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA Civil Action - Law No. OS-- 7173 In Custody ORDER OF COURT AND NOW, this _ of : ~"~'-~'~t~' based on the stipulation of the parties, the Court hereby Orders as follows: NOTi~,~: ~ ~A/t~l~ 1. Plaintiff(hereinafter'Wlother") and Defendant (hereinafter'~Father") shall have shared legal custody of their minor child, Rayna Craig, bom May 16, 1996. 2. Mother shall have primary residential custody of the child. 3. Father shall have partial custody as follows: a. On alternating weekends from Friday at 5:00 p.m. until Sunday at 7:00 p.m.; b. Two evenings eachweekasthepartiesmaymutuallyagree. Duringthe schoolyear, she shail be returned to Mother' s home by 8:00 p.m. During the summors, she shall be able to stay overnight with Father or be turned by 10:00 p.m. Exact arrangements shall be agreed upon by the parties. c. At other times mutually agreeable to the parties. Colleen R. Craig, Plaintiff Page 2 Stewart P. Craig, Defendant F.R. No. 4. Summers. Eachparent shallbe entitledtohaveperiodsofunintermptedcustodyastheymay mutually agree. 5. Holidays. Holidays shall be divided as the parties shall mutually agree. 6. Transportation. The parties shall agree to the transportation necessary for Father's periods of custody. 7. Mother shall claim the child on her income tax returns. ~. ~-':' vi" ;1 .... ~,,,m tu fi,* 3f' J,~ ',.[,,',,.I' Dlok 2,t F,....!-!:.. C~,,~,;y F~,-,,,,-l, h,~v L,sj,,,lodLdun uw~ 9. Plaintiffhas paid the filing costs for this matter. !0